Privacy Policy for Mosinian Research & Consultancy

Privacy Policy

Last updated: February 20, 2023

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use Our Services and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve Our Services. By using the Services, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Business (referred to as either "We", "Us", or "Our") refers to Mosinian Research & Consultancy, Limassol, Cyprus, Registration Number EE 56789. For the purposes of CCPA/CPRA, the Business is the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected, and that alone or jointly with others determines the purposes and means of the processing of Consumers' personal information, that does business in the State of California. For the purposes of the GDPR, the Business is the Data Controller.
  • CCPA and/or CPRA refers to California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
  • Consumer, for the purposes of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Country refers to: Cyprus
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Business as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Website such as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • GDPR refers to EU General Data Protection Regulation.
  • Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity. For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
  • Services refers to the services provided by the Business.
  • Service Provider means any natural or legal person who processes the data on behalf of the Business. It refers to third-party companies or individuals employed by the Business to facilitate the Services, to provide the Services on behalf of the Business, or to assist the Business in analyzing how the Services are used. For the purposes of the GDPR, Service Providers are considered Data Processors.
  • Website refers to Mosinian Research & Consultancy, accessible from www.mosinian.com.
  • You means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Services.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • First name and last name
  • Passport/ID number
  • Email address
  • Phone number
  • Address, State, Province, ZIP/Postal code, City

Cookies

Our Website uses Cookies. Cookies are small text files that are placed on Your Device. They are used to make Our Website work, or work more efficiently, as well as to provide Us information about how You use Our Website.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your Device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use the following types of Cookies for the purposes set out below:

Necessary / Essential Cookies

  • Administered by: Us
  • Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use certain features of the Website. For example, they allow Us to display Our Website in the proper format and language, to securely serve Our Website to You, to authenticate users and prevent fraudulent use of user accounts (where applicable), or to verify Your transactions (where applicable). Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Functionality Cookies

  • Administered by: Us
  • Purpose: These Cookies allow Us to remember important information and choices You make when You use the Website. Where You have previously indicated a preference, that preference will be stored in these Cookies. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

Analytics and Performance Cookies

  • Administered by: Us
  • Purpose: These Cookies allow Us to collect information about how You interact with Our Website. This includes, for example, the number of visitors to the Website, where visitors have come to the Website from, and the pages they visited. The purpose of these Cookies is to help to improve the way the Website works and in turn, to improve user experience. These Cookies are used on Our Website only when you acknowledge Our Cookie banner.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Website. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our Website may use Cookies.

Find out how to manage Cookies on popular browsers:

To find information relating to other browsers, visit the browser developer's website. To find out more about Cookies, visit www.aboutcookies.org or www.allaboutcookies.org.

Use of Your Personal Data

The Business may use Personal Data for the following purposes:

  • For the purposes of preparing, concluding, and performing a contract with You when You ask Us to provide You with Our Services.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers, and general information about other goods, services, and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct 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 Us about users of Our Services are among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and to evaluate and improve Our Services, products, services, marketing, and Your experience.

Retention of Your Personal Data

The Business will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

We will delete Your data if You terminate the Services or You request Us to erase Your Personal Data (see section "Delete Your Personal Data" below).

Please note that, even after You terminated the Services or asked Us to erase Your data, We may retain some of Your Personal Data where necessary to enable Us to meet Our legal obligations, to exercise or defend legal claims, or for other purposes as permissible by law. We also reserve the right to depersonalize Your data (remove all direct or indirect references to Your identity) and continue using it for Our own legitimate interests, such as for research and statistical purposes.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Business's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Business will take all steps reasonably necessary to ensure that Your data are treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

You may contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

We will not disclose Your personal information except in the following situations:

Service Providers

We may share Your personal information with Service Providers to perform Our Services, to monitor and analyze the use of Our Services, or to contact You.

Business Transactions

If the Business is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data are transferred and become subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Business may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Business may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Business
  • Prevent or investigate possible wrongdoing in connection with the Services
  • Protect the personal safety of Users of the Services or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Business is subject.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Business.

In any case, the Business will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Business undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. This enables You to receive a copy of the Personal Data We hold about You and other supplementary information about Our privacy practices with respect to Your Personal Data.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing them.
  • Request restriction of processing of Your Personal Data. This right exists in certain circumstances, for example, where We are considering a rectification or objection request made by You, or We no longer need the Personal Data for the purposes of the processing, but they are required by You for the establishment, exercise or defense of legal claims.
  • Request the transfer of Your Personal Data. We will provide to You or to a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Withdraw Your consent. You have the right to withdraw Your consent at any time if We are processing Your Personal Data with Your consent. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Services.
  • Complain to a Data Protection Authority about Our collection and use of Your Personal Data.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights by contacting Us.

Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible, and always within 30 days of receiving Your request.

If You wish to complain to a Data Protection Authority about Our collection and use of Your Personal Data and You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy Notice

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which We may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.

  • Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
  • Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

  • Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
  • Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

  • Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Collected: Yes.

Category D: Commercial information.

  • Examples: Records and history of products or services purchased or considered.
  • Collected: Yes.

Category E: Biometric information.

  • Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
  • Collected: No.

Category F: Internet or other similar network activity.

  • Examples: Interaction with Our Website or advertisement.
  • Collected: Yes.

Category G: Geolocation data.

  • Examples: Approximate physical location.
  • Collected: No.

Category H: Sensory data.

  • Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
  • Collected: Yes.

Category I: Professional or employment-related information.

  • Examples: Current or past job history or performance evaluations.
  • Collected: Yes.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

  • Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
  • Collected: No.

Category K: Inferences drawn from other personal information.

  • Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Collected: Yes.

Category L: Sensitive personal information.

  • Examples: Account login and password information, geolocation data.
  • Collected: No.

Under CCPA/CPRA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA/CPRA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms You complete on Our Website, or information You provide to Us by contacting Us.
  • Automatically from You. For example, through Cookies We or Our Service Providers set on Your Device as You navigate through Our Website.

Use of Personal Information

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

  • To operate Our Services and provide You with Our Services.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our Services.
  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about Our Services, We will use that personal information to respond to Your inquiry.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.
  • Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how We use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may disclose, and have disclosed in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

  • Service Providers

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is understood under CCPA/CPRA.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data are being used.

The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes, and share of personal information. Once We receive and confirm Your request, We will disclose to You:

  • The categories of personal information We collected about You
  • The categories of sources for the personal information We collected about You
  • Our business or commercial purposes for collecting or selling that personal information
  • The categories of third parties with whom We share that personal information
  • The specific pieces of personal information We collected about You
  • If We sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
    • The categories of personal information categories sold
    • The categories of personal information categories disclosed

The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information if We do so. We note that We do not sell personal information.

The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct Our Service Providers to correct) Your personal information, unless an exception applies.

The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods, unless an exception applies.

The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete Your personal information from Our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us to:

  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform Our contract with You.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

In order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

  • Verify Your identity or authority to make the request
  • And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Website does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If You would like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

Children's Privacy

Our Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

Links to Other Websites

Our Website may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us: