Last updated: [October 2025]

EWISE CYPRUS LIMITED (“EWISE” or “we”) is committed to protecting your privacy and handling your personal data transparently and lawfully. This notice (“Privacy Policy” or “Statement”) applies to personal information held by EWISE as a data controller, as described below, and also describes the processing of personal data concerning visitors to our website by EWISE and its affiliated companies.

This Privacy Policy may be further supplemented by other data protection notices provided by EWISE for specific uses of certain personal data in particular functionalities of our website. For example, when certain functions of our website request additional information from you, we may provide you with an additional notice to inform you about how we process such additional information.

We have prepared this Statement to explain our practices regarding personal data we collect from you or about you through the use of our website https://ewise.com.cy (the “Website”), including data you may provide when you contact us through the Website.

Specifically, this Privacy Policy:

  • Provides an overview of how EWISE collects and processes your personal data and informs you of your rights under the General Data Protection Regulation (GDPR) and any national law supplementing or implementing the GDPR;
  • Applies to natural persons who are visitors to the Website;
  • Contains important information regarding the personal data we collect, what we do with that data, to whom we may disclose it and for what purposes, as well as your rights concerning the personal data you have provided to us.

For the purposes of this Privacy Policy:

  • When we refer to “personal data”, we mean data that identifies or may identify you, which may include, for example, your IP address and information about how you interact with the Website;
  • When we refer to “sensitive data”, we mean special categories of personal data that uniquely identify an individual; the GDPR considers as sensitive personal data those that reveal the following: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) sexual life or sexual orientation; (6) physical or mental health or medical conditions; and (7) genetic and biometric data for the purpose of uniquely identifying a natural person;
  • When we refer to “processing”, we mean the management of your personal data by us, including its collection, protection, and storage; and
  • When we say or refer to “we”, “us”, or “EWISE”, we mean EWISE CYPRUS LIMITED, which acts as a data controller regarding your personal data when you visit the Website.

Note: Some links on the Website may lead to other EWISE entities or non-EWISE websites, which have their own privacy notices that may differ from this Statement. You should ensure that you agree with their privacy policies when using those other websites.

Information from Children

This Website is not intended for children, and we do not knowingly collect personal data about children.

1. Who We Are – EWISE CYPRUS LIMITED

EWISE CYPRUS LTD is a limited liability company (LLC), registered in the Republic of Cyprus under registration number 515, with its registered office at 6–8 Ayiou Prokopiou, Egkomi, 2406, Nicosia.

This Privacy Policy applies to personal data collected and managed by EWISE, its affiliated companies, and any other entities that may become affiliated with EWISE at any time, as applicable.

If you have any questions about this Privacy Policy or wish to obtain more information regarding the personal data we hold and process about you, please contact our Data Protection Officer (DPO) in writing at 6–8 Ayiou Prokopiou, Egkomi, 2406, Nicosia, Cyprus, via email at DataProtection@ewise.com.cy, or by telephone at 22 393175.

2. How We Collect Your Personal Data

We use various methods to collect personal data from and about you, including:

  • Your interaction with us: You may provide personal data through correspondence with us, for example, when you wish to give feedback or have questions regarding our products or services.
  • Automated technologies or interactions: As you interact with the Website, we automatically collect technical data about your equipment, actions, and browsing patterns. We collect these personal data using cookies and similar technologies.
  • Third parties: We may receive personal data about you from various third parties, including:
    • Analytics providers (e.g., Google);
    • Advertising networks (e.g., [x]);
    • Search information providers (e.g., [x]).

3. What Personal Data We Collect

We may collect the following personal data when you visit the Website:

  • Technical data: Such as your IP address, device type, domain type, browser type and version (e.g., Firefox, Chrome, Internet Explorer), date and time of access, browser plug-in types and versions, operating system and platform, device ID, and other technologies used on devices to access the Website.
  • Usage data: Such as information about how you interact with and use the Website.
  • Records of correspondence and/or communication we maintain with you.

Additionally, we collect, use, and share aggregated data, such as statistics, which are not considered personal data as they do not directly or indirectly reveal your identity. For example, we may aggregate user data to calculate the proportion of users using a specific Website function, analyze general trends in user interaction with the Website, and improve the Website and our services.

Recording: To help ensure your security and our business interests, we may record details of your interactions with us. This may include monitoring calls, emails, or other communications. We may use these recordings to review instructions, assess, analyze, and improve our services, train our staff, manage risks, or prevent and detect fraud and other crimes. Additionally, we may collect further information about these interactions, such as the phone numbers from which you contact us.

4. Why We Need Your Personal Data

4.1 Personal Data

We process and use your information when we have your consent or when there is a lawful reason to do so under applicable law. Common uses of your personal data include:

1. To comply with a legal obligation

We process your personal data when required to comply with legal and regulatory obligations, which may include processing personal data to comply with government authorities, court decisions, tax law, and other reporting requirements (e.g., credit checks by financial institutions or other authorities in the context of preventing money laundering and fraud) in the course of our business operations.

2. For legitimate interests

In some cases, we may process your personal data to pursue legitimate interests of our own or of third parties, provided that your rights and fundamental interests are not overridden. Specifically, we may process your personal data to:

  • Manage your requests, complaints, and inquiries;
  • Maintain our accounts and records;
  • Ensure the quality of our services;
  • Improve and tailor your experience on the Website;
  • Enhance the security of our network and information systems;
  • Identify, prevent, and investigate fraud or other unlawful activities, unauthorized transactions, claims, and other obligations, and manage risk exposure;
  • Ensure the security of our assets;
  • Modify or improve our products, services, and communications;
  • Defend, investigate, or pursue legal claims;
  • Obtain professional advice (e.g., tax or legal);
  • Perform data analysis (e.g., market research, trend analysis, financial analysis, and customer segmentation).

We do not expect to process sensitive data through the Website.

5. With Whom We May Share Your Personal Data

We may share your personal data with third parties as listed below. When we do so, we require these third parties to implement appropriate technical and organisational measures to protect your personal data. We will not share your personal data for purposes other than those described in this Privacy Policy, nor will we sell your personal data to anyone.

  • Service providers selected to support the operation of the Website, providing technological expertise, solutions, and support;
  • Auditors and accountants;
  • External legal advisors;
  • Cloud storage providers;
  • Financial and business consultants;
  • Government and regulatory authorities, to comply with legal and regulatory obligations, including law enforcement authorities regarding requests, proceedings, or investigations;
  • Affiliated companies of EWISE.

We may transfer personal data to recipients in third countries (i.e., countries outside the European Economic Area – EEA) only when we require compliance with European data protection standards and provide appropriate safeguards for the transfer of your data in accordance with the GDPR.

6. Data Protection

We use a range of administrative, technical, and technological measures to ensure that your information remains secure and protected, both physically and electronically. We require our staff and any third parties working on our behalf, or on our premises or servers, to comply with appropriate compliance standards, including obligations to protect any information and implement appropriate measures regarding the use and transfer of information.

7. Retention of Your Personal Data

We will retain your personal data only for as long as reasonably necessary to fulfill the purposes for which we collected them, including meeting any legal, regulatory, tax, accounting, or reporting obligations. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation concerning our relationship.

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 unauthorized use or disclosure of your personal data, the purposes for which we process the personal data, and whether we can achieve these purposes by other means, as well as applicable legal, regulatory, tax, accounting, or other requirements.

In some cases, you may request that we delete your data; see Section 8 below for further information.

We may need to retain your information for longer when required to comply with regulatory or legal obligations, or when necessary to protect legitimate business interests (e.g., due to limitation periods).

8. Your Rights

You have the following rights regarding the personal data and information we hold about you:

  • Access: To obtain access to your personal data. This allows you to receive a copy of the personal data we hold about you and to be informed about how we process it lawfully.
  • Correction: To request correction of personal data we hold about you. This allows you to rectify any incomplete, inaccurate, or outdated information.
  • Deletion: To request the deletion of your personal data. This allows you to ask us to erase or remove your personal data when there is no valid reason for us to continue processing it. However, we may continue to retain your information if we have a right or legal obligation to retain it under applicable law or if there is a legal interest (e.g., a claim against you or against EWISE).
  • Objection: To object to the processing of your personal data where we rely on legitimate interest and there is something regarding your particular situation that makes you wish to object. In such a case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.
  • Restriction: To request restriction of processing of your personal data. This allows you to request that we limit the processing of your personal data if:
    • It is inaccurate;
    • It has been processed unlawfully, but you do not want it deleted;
    • It is no longer relevant, but you want us to retain it for possible legal claims concerning you;
    • You have already asked us to stop using your personal data, but we are verifying whether we have lawful grounds to continue processing it.
  • Data portability: To request a copy of your personal data in a format that can be easily reused or to request the transfer of such data to other organizations.

Exercising Your Rights: To exercise any of your rights or if you have any other question regarding our use of your personal data, please contact our Data Protection Officer using the contact details provided in Section 1 of this Privacy Policy or by telephone. Our aim is to respond to your request as soon as possible. In some cases, this may take up to one month (if legally permitted). If we require more time to complete your request, we will inform you of the additional time needed and provide the reasons for the delay.

In some cases, we may reject your request. If permitted by law, we will inform you promptly of the reason for rejection. We make every effort to handle all requests promptly. If you are not satisfied with how we have addressed your concerns, you have the right to submit a complaint to us (see Section 9 – Right to Complain).

9. Right to Complain

If you have exercised any or all of your data protection rights, or still feel that your concerns regarding the use of your personal data have not been adequately addressed, you have the right to complain by contacting our Data Protection Officer using the contact details in Section 1 of this Privacy Policy or by visiting the Data Protection section on our website.

You also have the right to complain to the Office of the Commissioner for Personal Data Protection. You can visit their website at https://www.dataprotection.gov.cy.

10. Third-Party Links

Some links on our website lead to websites that do not belong to EWISE and have their own privacy notices, which may differ from this Statement. You should ensure that you agree with their privacy notices when using those other websites. We do not accept any responsibility or liability for the privacy policies of these third parties or for any personal data that may be collected through these websites or services. Please check these policies before submitting any personal data to these websites or using these services.

11. Changes to this Privacy Policy

We may modify and update this Privacy Policy from time to time without prior notice.

Changes will be posted on our website, and the revision date will be updated at the top of this page. However, we encourage you to review this Statement periodically so that you are always informed about how we process and protect your personal information.

12. Automated Decision-Making

We do not use automated decision-making concerning the personal data you provide through the Website.

Automated decision-making means a decision that produces legal effects concerning you or significantly affects you and is based solely on automated processing of data (i.e., without human intervention in the process), which aims to evaluate certain personal aspects related to data subjects.