1. Introduction
OPIUM WORKS, a subsidiary company of DIGITAL TREE E-PUBLISHERS LTD , hereinafter “we”, “us”,
“our” or the “Company”, is committed to privacy and secure processing of the personal data it
maintains for its customer and collaborators, in an open and transparent manner.
It is also committed to the collection and processing of this personal data in full compliance with the
General Regulation on the Protection of Personal Data of the European Union (Regulation 2016/679)
(hereafter referred to as "the Regulation") and the legislation in force in Cyprus, providing for the
Protection of Natural Persons with regard to the Processing of Personal Data and for the Free
Movement of such Data of 2018 (Law 125(I)/2018), that governs the collection and processing of
Personal Data of Individuals.
Thus, we have developed this Privacy Policy that governs the collection, use, disclosure, transfer and
storage of personal data. Please read our privacy practices carefully to understand our policies regarding
your data and how we will treat them and do not hesitate to contact us for any questions.

2. Our role under the Regulation
Under the Regulation, OPIUM WORKS may be operating as the Data Controller or Data Processor for all
the personal data it maintains and processes.
As a Data Controller, OPIUM WORKS in certain cases is allowed to collect, maintain and process the
personal data of all customers and collaborators.
As a Data Processor, OPIUM WORKS will process personal data as per the means and purposes defined
by the Data Controller. We collect information under the direction of the Data Controller and have no
direct relationship with the individuals whose personal data we process in connection with the use of
our Services.
If you are an individual who interacts with a customer using our Services, that customer is the Data
Controller of your personal data and you should contact them directly for assistance with any requests
or inquiries to your personal data.
3. How are Personal Data Collected
This privacy policy applies to Data we collect:
● directly from you when we collaborate, or you use our Services
● through third parties in the standard course of the business we do in order to provide you with the
service you requested
● through our website(s), such as through cookies or by using the Contact us or Career form to
communicate with us
● through our Social Media accounts

4. Types of Personal Data Collected

We collect and use several types of data, including Data by which subjects may be identified ("Personal
Data" means any Data relating to an identified or identifiable natural person (‘data subject’); an
identifiable natural person is one who can be identified, directly or indirectly, in particular by reference
to an identifier such as a name, an identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity
of that natural person).
Such data might include your first and last name, identity number, e-mail address, address and post
code, contact number, education details and training records, employment data, financial and/or
banking data, photographs and videos, as well as other Data related to cookies, online identifiers,
demographics and other (online) contact Data, always in regards to the relationship we have with you.
Further to other media of collection, we collect and use Data, on or through our Website(s) or Social
Media Accounts, including:
● Data that you provide by filling in forms, in particular at the time of first contact with us.
● Data when you enter a contest or promotion sponsored by us, and when you report a problem with
our Website(s).
● Employment data when you fill out our Careers forms on our Website(s) or contact us through email
for an employment opportunity
● Records and copies of your correspondence (including email addresses)

5. Purposes for Which We Use Your Personal Data
In general, we might process your personal data for the following purposes:
● Provision of Services: to provide you with data, products or services that you request from us;
● Customer management: to manage your account, to provide you with customer support, notices
about your account and information about changes and/or updates to any products or services we
offer to you;
● Advertising: following explicit consent to communicate with you about products or services that may
be of interest to you;
● Functionality and security: to detect, prevent, and respond to actual or potential fraud, illegal
activities, or intellectual property infringement;
● Compliance: to enforce our terms and conditions and to comply with our legal obligations as these
derive from the applicable laws or our regulators;
● for any other purpose with your consent.
● Communication in response to your application or inquiry for an employment opportunity
6. Disclosure of Your Personal Data
We do not share your Personal Data with third parties except as indicated below:
● Affiliates. We share Personal Data with our subsidiaries and affiliates to the extent this is necessary
for the purposes of provision of services, customer management, customization of content,

advertising (if you have consented), security and compliance, or to the extent you have provided
your consent.
● Service providers. To our authorized service providers that perform certain services on our behalf,
including for purposes of provision of the services you requested from us, customer management
and security. These service providers may have access to Personal Data needed to perform their
functions but are not permitted to share or use such data for any other purposes. We have taken all
reasonable steps to ensure that they comply with the current data protection regulations.
● Legal successors. To a buyer or other successor in the event of a merger, divestiture, restructuring,
reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going
concern or as part of bankruptcy, liquidation or similar proceeding, in which personal Data held by is
among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to
try to ensure that the entity to which we transfer your personal Data uses it in a manner that is
consistent with this privacy policy.
We also disclose your Personal Data to other third parties, including official authorities, courts, or other
public bodies:
● In response to a subpoena or similar investigative demand, a court order or other judicial or
administrative order, or a request for cooperation from a law enforcement or other government
agency; to establish or exercise our legal rights; to defend against legal claims; to comply with
applicable law or cooperate with law enforcement, government or regulatory agencies; or to enforce
our Website terms and conditions or other agreements or policies; or as otherwise required by law
(including responding to any government or regulatory request). In such cases, we may raise or
waive any legal objection or right available to us, in our sole discretion.
● To the extent a disclosure is necessary in connection with efforts to investigate, prevent, report or
take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and
defend the rights, property or safety of our Company, our users, our employees, or others; to
maintain and protect the security and integrity of our Website or infrastructure.
We may disclose aggregated Data about subjects, and Data that does not identify any individual,
without restriction. In particular, We may transfer non-Personal Data and process it outside your
country of residence. We may combine non-Personal Data we collect with additional non-Personal Data
collected from other sources. We also may share aggregated Data with third parties, including advisors,
advertisers and investors, for the purpose of conducting general business analysis.

7. How We Store Your Personal Data
The Data that we collect about you, including Personal Data, is safely stored and processed in Cyprus
and/or in remote cases in Countries within the European Union.
8. Retention of Personal Data
The period for which we keep your Personal Data that is necessary for compliance and legal
enforcement purposes varies and depends on the nature of our legal obligations and claims in the
individual case.

To the extent we have collected your Personal Data for the purposes mentioned in Section 5, we keep
your Personal Data for as long as you have an active relationship with us, as needed to provide you with
our respective services and in compliance with relevant laws of Cyprus. For further Data regarding
specific retention period please contact us at [email protected]

9. Legal Basis for Collection, Use and Disclosure of Your Personal Data
There are different legal bases that we rely on to collect, use and disclose your Personal Data, namely:
● Consent: We will rely on your consent to use (i) your Personal Data for marketing and advertising
purposes; (ii) your Personal Data for other purposes when we ask for your consent and for which the
purpose of the process does not relate to the services, we offer to you.
● Performance of contract: The use of your Personal Data for purposes of providing the services,
customer management and functionality and security as described above is necessary to perform the
services provided to you under our term and conditions and any other contract that you have with
● Compliance with legal obligation: We are permitted to use your Personal Data to the extent this is
required to comply with a legal obligation to which we are subject.
● Protection of your vital interests: The processing of your Personal Data is necessary to protect your
vital interests, if you are physically or legally incapable of giving consent.
Protection of our legitimate interests: The processing of your Personal Data is necessary for the
purposes of the legitimate interests pursued by us or by a third party, except where such interests are
overridden by your interests or fundamental rights and freedoms which require protection of personal
data, in particular where the data subject is a child.

10. How We Protect the Security of Your Personal Data
We take appropriate security technical and organisational measures (including physical, electronic and
procedural measures) to safeguard your Personal Data from unauthorized access, unlawful use,
intervention, modification or disclosure under the requirements of the Regulation. For example, only
authorized employees are permitted to access Personal Data, and they may do so only for permitted
business functions. In addition, we have trained our employees on how to handle, manage and process
personal data, applied upgraded technical measures and transformed our policies and procedures in a
way that will comply with the General Data Protection Regulation.
11. Automated Decision-Making, Including Profiling
We reserve the right to use automated decision-making in the following cases: When deemed necessary
to provide services to you, with your written, express consent, and if the appropriate measures have
been taken to safeguard your rights.
12. Choices About How We Collect, Use and Disclose Your Personal Data
We strive to provide you with choices regarding the Personal Data you provide to us.

You can choose not to provide us with certain Personal Data, but that may result in you being unable to
use certain services.
When you collaborate with us, you may be given a choice as to whether you want to receive email
messages, newsletters or advertising material about our services, improvements, performance, special
offers, or containing special distributions of content by us. If consented yet later on you decide you no
longer want to receive commercial or promotional emails or newsletters from us, you will need to avail
yourself of the unsubscribe mechanism set out in the applicable communication or submit to us your
request through email. It may take up to thirty days for us to process an opt-out request.
If you provided Personal Data, you may terminate your relationship with us at any time as per the
provision of the between us agreement or engagement. If you choose to do so, your Personal Data will
be deleted in accordance with our retention policy.
Subject to the provisions of the General Data Protection Regulation, you have the following rights in
regard to your Personal Data: (Please note, these rights are not absolute and in some cases, they are
subjected to conditions as defined by law)
1. Right of Access – You have the right to access your own Personal Data, as well as the right to
request a copy of your personal data that is maintained and processed by our Company.
2. Right of Rectification - You have the right to request the correction of any incomplete and / or
inaccurate Personal Data we hold for you.
3. Right to Erasure - You have the right to request the deletion of Personal Data only if one of the
following reasons is true:
(i) Personal Data are no longer necessary in relation to the purposes for which they were
collected or processed.
(ii) If the processing is based on your consent and you have withdrawn this consent (on which
processing is based) in accordance with Articles 6.1.a and 9.2.a of the Regulation and if no
other legal basis for processing, applies.
(iii) If you object to processing in accordance with Article 21.1 of the Regulation, there are no
compelling and legitimate reasons for processing.
(iv) If Personal Data has been processed illegally.
(v) If Personal Data should be deleted in compliance with a legal obligation under Union law
to which our Company is subject to.
(vi) If the personal data have been collected in relation to the provision referred to in Article
8.1 of the Regulation.
4. Right to Object - You have the right to oppose the processing of your Personal Data at any time
and for reasons related to a specific situation, unless there are compelling legitimate reasons for
processing that override your interests, rights and freedoms.
5. Right to Restriction of Processing - You reserve the right to request the restriction of processing
on your Personal Data so that we may no longer process the specific Data until the restriction is
lifted (for example, the data have been corrected).
6. Right to Data Portability - You have the right to request the transfer of your personal data that
you have provided to our Company. These data will be given to you in a format that is
structured, widely used and machine readable and, in certain cases you may also have the right

to request for us to send the Data to another organization, provided that such a transfer is
technically feasible.
7. Right to Object and Automated Individual Decision-Making (Including Profiling) - You have the
right to request that we do not make any decision, regarding you, solely on the basis of
automated processing, including profiling, only in the case that this decision has legal or
significant consequences on you.
If you have any questions in regard to the kind of personal data we hold for you, or if you want to
exercise any of your personal data rights, please send a written request to the email
[email protected] or to the postal address provided at the bottom of this Privacy Policy. However,
we reserve the right to reject any requests for access or for imposing restrictions or other claims if
required or permitted by the law.

13. Changes to Our Privacy Policy
We may modify or revise our privacy policy from time to time. Although we may attempt to notify you
when major changes are made to this privacy policy, you are expected to periodically review the most
up-to-date version found at our website so you are aware of any
changes, as they are binding on you.
If we change anything in our privacy policy, the date of change will be reflected in the “last modified
date” below. You agree that you will periodically review this privacy policy and refresh the page when
doing so. You agree to note the date of the last revision to our privacy policy. If the “last modified” date
is unchanged from the last time you reviewed our privacy policy, then it is unchanged. On the other
hand, if the date has changed, then there have been changes, and you agree to re-review our privacy
policy, and you agree to the new ones. By continuing to use the Website(s), subsequent to us making
available an amended version of our privacy policy in a way that you can easily take notice of it, you
thereby consent to such amendment.
14. No Rights of Third Parties
This privacy policy does not create rights enforceable by third parties or require disclosure of any
Personal Data relating to users of the Website.
15. No Error Free Performance
We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to
comply with this privacy policy and will take prompt corrective action when we learn of any failure to
comply with our privacy policy. We shall not be liable for any incidental, consequential or punitive
damages relating to this privacy policy.
16. Contact Data
If you have any questions about this privacy policy or our Data-handling practices, please contact us at
[email protected]

You may also contact us at 8 Michael Karaoli, Anemomylos Building, 4rth floor, Nicosia 1095, Cyprus,
telephone +357- 22396999
Submission of a Complain: If you feel that your concerns in regard to the use of your personal data or
any of your data protection rights have not been addressed by us, you have the right to contact us at
[email protected] and submit a complaint. You also have the right to submit a complaint with the
Personal Data Protection Commissioner’s Office at

Last Modified date: 10.6.2021

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