Visual Voices Privacy Policy

Welcome to the VISUAL VOICES (VV) privacy policy.

Visual Voices respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law prote
cts you.

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how VV collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or receive a project or service or take part in a competition or when becoming a user.

This website is not intended for children, and we only collect data relating to children provided that their parent’s and/or guardian’s written and express consent being provided.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER 

VV is the controller and responsible for your personal data (collectively referred to as” “ORGANIZATION”, “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us on contact@visual-voices.org using the details set out below.

CONTACT DETAILS 

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Visual Voices

Email address: contact@visual-voices.org

Postal address: Antigonou, 3, 1016 Nicosia, Cyprus

Telephone number: +35799362828

You have the right to make a complaint at any time to the Data Protection Commissioner’s Office (DPCO), the Cyprus supervisory authority for data protection issues (http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_en/home_en?opendocument ). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES 

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS 

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.  THE DATA WE COLLECT ABOUT YOU 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·    Identity Data includes first name, maiden name, last name, or similar identifier.

·    Contact Data includes email address, and in some occasion phone numbers.

·    Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

·    Profile Data includes your interests, preferences, feedback, and survey responses.

·    Usage Data includes information about how you use our website, projects, and services.

·    Communications Data includes your preferences in receiving communication from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy


3.  HOW IS YOUR PERSONAL DATA COLLECTED? 

We use different methods to collect data from and about you including through:

·    Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you: apply for our projects or services; request communication to be sent to you; sign an agreement or an Memorandum of Understanding (MOU); enter a survey; or give us feedback or contact us.

·    Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies.

·    Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:  analytics providers, advertising networks,  search information providers, such as Google, based inside or outside the EU.
 
·    Contact, Financial and Transaction Data from providers of technical, donation and delivery services such as Wise, based inside or outside the EU.

·    Identity and Contact Data from publicly available sources.


4.  HOW WE USE YOUR PERSONAL DATA 
 
We will only use your personal data when the law requires us to. Most commonly, we will use your personal data in the following circumstances:

·    Where we need to perform the contract, we are about to enter into or have entered into with you.

·    Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

·    Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct communications to you via email. You have the right to withdraw consent to communication at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 

We have set out below, ia description of all the ways we could use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity
 
To register you as a new beneficiary, or donor or collaborator or volunteer; To enable you to partake in an open call, competition or complete a survey;  To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); To deliver relevant website content and communications to you and measure or understand the effectiveness of the communications we serve to you;  To use data analytics to improve our website, projects/services, communication, relationships and experiences ( (a) Technical, (b) Usage).

COMMUNICATION 


We strive to provide you with choices regarding certain personal data uses, particularly around communication.


We may use your Identity, Technical, Usage Data to form a view on what we think may be of interest to you. This is how we decide which projects, services and calls may be relevant for you. You will receive communications from us if you have requested information from us and you have not opted out of receiving that communication.


THIRD-PARTY COMMUNICATION 

We will get your express opt-in consent before we share your personal data with any third party for communication purposes.


OPTING OUT 

You can ask us or third parties to stop sending you messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your communication preferences OR by following the opt-out links on any message sent to you OR by contacting us at any time.

Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of a project/service received, warranty registration, project/service experience or other transactions.


COOKIES 


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.


CHANGE OF PURPOSE 


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


5.  DISCLOSURES OF YOUR PERSONAL DATA 


We may share your personal data with the parties set out below for the purposes set out in the table above.

·    Internal Third Parties as set out in the Glossary.

·    External Third Parties as set out in the Glossary.

·    Specific third parties listed in the table Purposes for which we will use your personal data above.

·    Third parties to whom we may choose to transfer or merge parts of our organisation. Alternatively, we may seek to merge with other organisations. If a change happens to our organisation, then the new governing body may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


6.  INTERNATIONAL TRANSFERS 


We share your personal data within Google Inc. This will involve transferring your data in or outside the European Economic Area (EEA). Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

·    We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

·    Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

·    Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


7.  DATA SECURITY 


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have an organisation need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


8.  DATA RETENTION 


HOW LONG WILL YOU USE MY PERSONAL DATA FOR? 


We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


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 unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.


By law we have to keep basic information about our collaborators/ donors/beneficiaries/ volunteers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being collaborators/ donors/beneficiaries/ volunteers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.


In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


9.  YOUR LEGAL RIGHTS 


Under certain circumstances, you have rights under data protection laws in relation to your personal data listed below:

·    Request access to your personal data.

·    Request correction of your personal data.

·    Request erasure of your personal data.

·    Object to processing of your personal data.

·    Request restriction of processing your personal data.

·    Request transfer of your personal data.

·    Right to withdraw consent.

Please refer to the Glossary section (paragraph 10) for further guidance.

If you wish to exercise any of the rights set out above, please contact us.


NO FEE USUALLY REQUIRED 


You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.


WHAT WE MAY NEED FROM YOU 


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


TIME LIMIT TO RESPOND 


We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


10.  GLOSSARY 


LAWFUL BASIS 


Legitimate Interest means the interest of our organisation in conducting and managing our organisation to enable us to give you the best service/project and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


THIRD PARTIES 


INTERNAL THIRD PARTIES 

Other companies in the Group acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting.


EXTERNAL THIRD PARTIES 

Includes the following:


·    Service providers based inside or outside the EEA acting as processors who provide IT and system administration services.

·    Professional advisers including lawyers, bankers, auditors and insurers based inside or outside the EEA who provide consultancy, banking, legal, insurance and accounting services.

·    HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based inside or outside the EEA who require reporting of processing activities in certain circumstances.


YOUR LEGAL RIGHTS 

You have the right to:


Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct communication purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:


·    If you want us to establish the data’s accuracy.

·    Where our use of the data is unlawful, but you do not want us to erase it.

·    Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

·    You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain projects or services to you. We will advise you if this is the case at the time you withdraw your consent.



Terms of Use of Visual Voices Website



PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS SITE 

WHAT’S IN THESE TERMS


These terms tell you the rules for using our website www.visual-voices.org  (our site).


WHO WE ARE AND HOW TO CONTACT US 


www.visual-voices.org is a site operated by Visual Voices (“We” or “VV”). We are registered in the Republic of Cyprus under non-profit company number HE386100 and have our registered office at Antigonou 3, Cyprus.


We are a private non-profit organisation.


To contact us, please email contact@visual-voices.org or telephone/whatsapp/viber  on +35799362828


BY USING OUR SITE, YOU ACCEPT THESE TERMS 


By using our site, you confirm that you accept these terms of use and that you agree to comply with them.


If you do not agree to these terms, you must not use our site.


We recommend that you print a copy of these terms for future reference.


THERE ARE OTHER TERMS THAT MAY APPLY TO YOU 


These terms of use refer to the following additional terms, which also apply to your use of our site:


·    Our Privacy Policy . See further under How we may use your personal information.

·    Our Acceptable Use Policy, which sets out the permitted uses and prohibited uses of our site. When using our site, you must comply with this Acceptable Use Policy.

·    Our Cookie Policy, which sets out information about the cookies on our site.


WE MAY MAKE CHANGES TO THESE TERMS 


We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time.


WE MAY MAKE CHANGES TO OUR SITE 


We may update and change our site from time to time. We will try to give you reasonable notice of any major changes.


WE MAY SUSPEND OR WITHDRAW OUR SITE 


Our site is made available free of charge.


We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.


You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.


WE MAY TRANSFER THIS AGREEMENT TO SOMEONE ELSE 


We may transfer our rights and obligations under these terms to another organisation. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under the contract.


HOW YOU MAY USE MATERIAL ON OUR SITE 


We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others within your organisation to content posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged.

You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy, or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.


DO NOT RELY ON INFORMATION ON THIS SITE 


The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site.

Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete, or up to date.


WE ARE NOT RESPONSIBLE FOR WEBSITES WE LINK TO 


Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.


We have no control over the contents of those sites or resources.


USER-GENERATED CONTENT IS NOT APPROVED BY US 


This website may include information and materials uploaded by other users of the site, including to bulletin boards and chat rooms. This information and these materials have not been verified or approved by us. The views expressed by other users on our site do not represent our views or values.


HOW TO COMPLAIN ABOUT CONTENT UPLOADED BY OTHER USERS 


If you wish to complain about content uploaded by other users, please contact us on contact@visual-voices.org


HOW WE MAY USE YOUR PERSONAL INFORMATION 

We will only use your personal information as set out in our privacy policy.


UPLOADING CONTENT TO OUR SITE 

Whenever you make use of a feature that allows you to upload content to our site, or to make contact with other users of our site, you must comply with the content standards set out in our Acceptable Use Policy.

You warrant that any such contribution does comply with those standards, and you will be liable to us and indemnify us and keep us indemnified for any breach of that warranty. This means you will be responsible for any loss or damage we suffer as a result of your breach of warranty.

Any content you upload to our site will be considered non-confidential and non-proprietary. You retain all of your ownership rights in your content, but you are required to grant us, and hereby grants us, a limited licence to use, store and copy that content and to distribute and make it available to third parties. 

We also have the right to disclose your identity to any third party who is claiming that any content posted or uploaded by you to our site constitutes a violation of their intellectual property rights, or of their right to privacy.

We have the right to remove any posting you make on our site if, in our opinion, your post does not comply with the content standards set out in our Acceptable Use Policy.

You are solely responsible for securing and backing up your content.

We do not store terrorist content.


WE ARE NOT RESPONSIBLE FOR VIRUSES AND YOU MUST NOT INTRODUCE THEM 

We do not guarantee that our site will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored, or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under applicable law. We will report any such breach to the relevant law enforcement authorities, and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.


RULES ABOUT LINKING TO OUR SITE 


You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.

You must not establish a link in such a way as to suggest any form of association, approval, or endorsement on our part where none exists.

You must not establish a link to our site in any website that is not owned by you.

Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page.

We reserve the right to withdraw linking permission without notice.

The website in which you are linking must comply in all respects with the content standards set out in our Acceptable Use Policy.

If you wish to link to or make any use of content on our site other than that set out above, please contact contact@visual-voices.org 


WHICH COUNTRY’S LAWS APPLY TO ANY DISPUTES? 


Please note that the terms of this policy, its subject matter and its formation are governed by the laws of the Republic of Cyprus. You and we both agree that the courts of the Republic of Cyprus will have exclusive jurisdiction.



Visual Voices Website Acceptable Use Policy



PLEASE READ THE TERMS OF THIS POLICY CAREFULLY BEFORE USING THE SITE 


This acceptable use policy sets out the content standards that apply when you upload content to our site, contact other users on our site, link to our site, or interact with our site in any other way.


WHO WE ARE AND HOW TO CONTACT US 

www.visual-voices.org  is a site operated by Visual Voices (” We”). We are registered in the Republic of Cyprus under non-profit company number HE386100 and have our registered office at Antigonou 3, Cyprus.  We are a private non-profit organisation.


To contact us, please email contact@visual-voices.org or telephone/whatsapp/viber on +35799362828

We are a private non-profit company limited by guarantee without capital approved as a non-profit organisation pursuant to section 28 of the Companies Law CAP. 113 of the Laws of Cyprus.

 
BY USING OUR SITE, YOU ACCEPT THESE TERMS 


By using our site, you confirm that you accept the terms of this policy and that you agree to comply with them.
  
If you do not agree to these terms, you must not use our site.

We recommend that you print a copy of these terms for future reference.



WE MAY MAKE CHANGES TO THE TERMS OF THIS POLICY 

We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. 

 
PROHIBITED USES 

You may use our site only for lawful purposes. You may not use our site:


·    In any way that breaches any applicable local, national, or international law or regulation.

·    In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.

·    For the purpose of harming or attempting to harm minors in any way.

·    To bully, insult, intimidate or humiliate any person.

·    To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards found on this document.

·    To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).

·    To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

·    Not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our terms of website use found on this document.

·    Not to access without authority, interfere with, damage, or disrupt:

·    any part of our site.

·    any equipment or network on which our site is stored.

·    any software used in the provision of our site; or

·    any equipment or network or software owned or used by any third party.

 
INTERACTIVE SERVICES 
 

We may from time to time provide interactive services on our site, including, without limitation:

·    Chat rooms.

·    Bulletin boards.

(Interactive services.)
Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not fool proof. Minors who are using any interactive service should be made aware of the potential risks to them.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.


CONTENT STANDARDS 


These content standards apply to any and all material which you contribute to our site (Contribution), and to any interactive services associated with it.


The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole.

Visual Voices will determine, in its discretion, whether a Contribution breaches the Content Standards.

A Contribution must:

·    Be accurate (where it states facts).

·    Be genuinely held (where it states opinions).

·    Comply with the law applicable in the Republic of Cyprus and in any country from which it is posted.


A Contribution must not:

·    Be defamatory of any person.

·    Be obscene, offensive, hateful, or inflammatory.

·    Bully, insult, intimidate or humiliate.

·    Promote sexually explicit material.

·    Include child sexual abuse material.

·    Promote violence.

·    Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation, or age.

·    Infringe any copyright, database right or trademark of any other person.

·    Be likely to deceive any person.

·    Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.

·    Promote any illegal activity.

·    Be in contempt of court.

·    Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience, or needless anxiety.

·    Be likely to harass, upset, embarrass, alarm, or annoy any other person.

·    Impersonate any person or misrepresent your identity or affiliation with any person.

·    Give the impression that the Contribution emanates from VIVOS, if this is not the case.

·    Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse.

·    Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation, or instigation of acts of terrorism.

·    Contain any advertising or promote any services or web links to other sites.


BREACH OF THIS POLICY 

When we consider that a breach of this acceptable use policy has occurred, we may take such action as we deem appropriate.

Failure to comply with this acceptable use policy constitutes a material breach of the terms of use here upon which you are permitted to use our site, and may result in our taking all or any of the following actions:

·    Immediate, temporary, or permanent withdrawal of your right to use our site.

·    Immediate, temporary, or permanent removal of any Contribution uploaded by you to our site.

·    Issue of a warning to you.

·    Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.

·    Further legal action against you.

·    Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude all and any liability for all action we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

WHICH COUNTRY’S LAWS APPLY TO ANY DISPUTES? 

Please note that the terms of this policy, its subject matter and its formation are governed by the laws of the Republic of Cyprus. You and we both agree that the courts of the Republic of Cyprus will have exclusive jurisdiction.

Cookies

Our Site uses cookies – small text files created and stores on your web browser when you visit the website – to monitor browsing preferences also supports certain parts of our website to function properly. When you use and access the Site, we may place cookies in your web browser. Cookies allow our Site to distinguish you from other users to enhance your experience. 

We may use mandatory cookies to authenticate users and prevent fraudulent use of user accounts. We also use cookies to enable certain functions of the Site, to provide analytics, to store your preferences, and to enable marketing. The data we collect in this process will not identify you as individual, as they do not contain personal information.

If you would like to disable cookies, we recommend you visit the help pages of your web browser. Please note, however, that if you delete or refuse cookies, you might not be able to use all the features we offer, you may not be able to store your preferences, and some of our pages, text or diagrams might not display properly.

You can find more information about cookies in the following third-party websites:

·    AllAboutCookies: http://www.allaboutcookies.org/ 

·    Network Advertising Initiative: http://www.networkadvertising.org/

If you have any questions about the cookies policy, please contact us at contact@visual-voices.org



PROCEDURE FOR DATA SUBJECTS’ EXCERCISE OF RIGHTS


 INTRODUCTION:

This procedure refers to how employees of Visual Voices respond to persons who wish to exercise rights with regards to their personal data held by Visual Voices.

To exercise such rights, these persons (data subjects) must use the following forms:

Form 1: Erasure Request

Form 2: Access Request

Form 3: Rectification Request

Form 4: Data Portability Request

Form 5: Processing Restriction Request

Form 6: Processing Objection Request

 
STAGE 1: FORM SUBMISSION

A. Form Submissions

Form submitted by hand at the Offices of Visual Voices:
1)     The form is submitted by the data subject or the data subject’s authorised representative, only to the Director or in the absence thereof, to an employee of Visual Voices.

2)     Upon collecting the form, the Director or employee of Visual Voices shall:
  • Ensure that the form has been completed and signed accordingly.
  • If the form is submitted by the data subject, check all necessary identification documents that will allow them to verify that the person submitting the form is the same person as the data subject to which the form refers or if the form is submitted by an authorised representative of the data subject, check all necessary identification and authorisation documents that will allow them to identify the data subject, to identify the authorised representative and to verify that the person submitting the form has appropriate authorisation by the data subject. 
  • Fill out and sign the receipt verification part of the form and make a copy. 
  • Make a copy of the form and deliver to the data subject or the data subject’s authorised representative the copy of the form. 
  • Place the form along with the identification and authorisation documents in a sealed envelope separately from any other documents.
  • If it is an employee of the Visual Voices who has received the form, then the employee should hand the sealed envelope to the Director immediately.
  • Ensure that the sealed envelope is delivered to the Director personally.

The Director should open the Form.

Form submitted by email

1)     Any employee receiving any email communication by a data subject or an authorised representative of a data subject, seeking to exercise a right with regards to the data subject’s personal data, shall forward the email to the Director.

2)     Upon receiving such forwarded email or upon receiving such an email communication directly by a data subject or an authorised representative of a data subject, the Director, shall take the following steps:

i. If the relevant form has been used, ensure that the form has been completed and signed accordingly.
ii. If the relevant form has not been used, send the relevant form by email to the data subject or to the authorised representative of the data subject and request the form to be completed and signed and returned by email.
iii. If the form is submitted by the data subject, collect all necessary identification documents that will allow the Director to verify that the person submitting the form is the same person as the data subject to which the form refers or if the form is submitted by an authorised representative of the data subject, collect all necessary identification and authorisation documents that will allow the Director to identify the data subject, to identify the authorised representative and to verify that the person submitting the form has appropriate authorisation by the data subject.
iv. Call the data subject at the telephone number already stored in the company’s records to verify the validity of the form submission.

B. Deadline for responding to the data subjects’ request

Upon signing the receipt verification part of the form, the company must respond to the data subject’s request within 30 days.

STAGE 2: VERIFICATION

Upon collection of the form and any necessary identification and authorisation documents, Director, shall first verify whether the data subject is a person for which Visual Voices holds personal data. For the purpose of verification, the Director shall coordinate with other employees of the company if necessary.

If the data subject is not a person for which Visual Voices holds personal data, the Director shall send a written notification to the person who has submitted the form, informing that:

·      the data subject is not a person for which Visual Voices holds personal data.

·      the form cannot be further examined.

·      the form along with any identification and authorisation documents that have been collected and a copy of this notice (including any other previous notices or communication exchanged) will be stored for a period of 1 year of the date of the notice or for a period not exceeding 3 months after the end of the original retention period whichever period is greater. This is so, for the purposes of the legitimate interests of Visual Voices, in showing compliance with its obligations under personal data protection legislation.

STAGE 3: EVALUATION – RECOMMENDATION - DECISION

If the data subject is indeed a person for which Visual Voicesholds personal data, the Director accordingly shall evaluate if and how the data subject’s right can be exercised in the manner specified in the form.

For the purpose of evaluation, it is necessary for the Director, to establish the following:

·      the types of personal data held by Visual Voices.

·      where and in what form the personal data is stored.

·      the third parties with which the personal data has been shared.

·      the purposes for which the personal data has been collected, shared and stored, as may be applicable.

·      the legal basis for all processing activities related to the personal data.

·      the impact of allowing the data subject to exercise the right in the manner specified in the form.

In order to carry out the above evaluation, the Director, shall coordinate with other employees of the company.

In deciding as to how the data subject’s right may be exercised, the Director, shall take into consideration the following factors:

·      the results of the evaluation

·      the Visual Voices Privacy Policy that is applicable to the data subject

·      the provisions of data protection legislation

STAGE 4: NOTICE

Upon reaching a decision, the Director shall send a written notice to the person who has submitted the form, informing of the company’s decision as to how the data subject’s right may be exercised.

A. If the company’s decision is not to allow the data subject to exercise the right as described in the form, the Director shall include in the notice the reasons for the decision and also inform:

·      that the data subject has a right to file a complaint with the supervising authority and the contact details thereof;

·      that the form along with any identification and authorisation documents that have been collected and a copy of this notice (including any other previous notices or communication exchanged) will be stored for a period of 1 year of the date of the notice or for a period not exceeding 3 months after the end of the original retention period whichever period is greater. This is so, for the purposes of the legitimate interests of Visual Voices, in showing compliance with its obligations under personal data protection legislation.

B. If the company’s decision is only to partially allow the data subject to exercise the right as described in the form or under specific conditions, the Director shall include in the notice the reasons for the decision and also inform:

·      the way in which the data subject will be allowed to exercise the right;

·      any conditions to be satisfied by the recipient of the notice in order to be allowed to exercise the right and the deadline in which to do so;

·      that the data subject has a right to file a complaint with the supervising authority and the contact details thereof

If any of the conditions that have been set in the notice are not satisfied within the deadline, then the Director shall send a new written notice to the person who has submitted the form, informing of the company’s decision not to allow the data subject to exercise the right shall include in the notice the reasons for the decision and also inform:

·      that the data subject has a right to file a complaint with the supervising authority and the contact details thereof;

·      that the form along with any identification and authorisation documents that have been collected and a copy of this notice (including any other previous notices or communication exchanged) will be stored for a period of 1 year of the date of the notice or for a period not exceeding 3 months after the end of the original retention period whichever period is greater. This is so, for the purposes of the legitimate interests of Visual Voices, in showing compliance with its obligations under personal data protection legislation.


STAGE 5: IMPLEMENTATION MEASURES

The Director shall take all necessary measures to implement the decision of the higher management as to the way in which the data subject will be allowed to exercise the right. In doing so the Director shall coordinate with any other employees of Visual Voices as required.

Upon taking all necessary measures to implement the decision, the Director shall send a written notice to the person who has submitted the form, informing:

·      the measures that have been taken to implement the decision

·      that the form along with any identification and authorisation documents that have been collected and a copy of this notice (including any other previous notices or communication exchanged) will be stored for a period of 1 year of the date of the notice or for a period not exceeding 3 months after the end of the original retention period whichever period is greater. This is so, for the purposes of the legitimate interests of Visual Voices, in showing compliance with its obligations under personal data protection legislation.


GENERAL PROVISIONS

If at any stage of the above procedure, the person who has submitted the form or the data subject (if the form has been submitted by an authorised representative) submits a written notice of withdrawal of the form, or a written notice that the authorisation to the representative has been cancelled or is invalid, then the Director shall take no further action with regards to the form and shall send a written notice to the person who has submitted the notice, informing:

·      that due to the notice, no further action shall be taken with regards to the form
that the form along with any identification and authorisation documents that have been collected and a copy of this notice (including any other previous notices or communication exchanged) will be stored for a period of 1 year of the date of the notice or for a period not exceeding 3 months after the end of the original retention period whichever period is greater. This is so, for the purposes of the legitimate interests of Visual Voices, in showing compliance with its obligations under personal data protection legislation.




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