Privacy Policy

1. Scope and Application

This privacy policy, as such may be amended, supplemented or modified from time to time, ("Privacy Policy") sets out the privacy principles, practises and controls exercised by G.D. BINARYHELIX LIMITED, a company incorporated and existing in the Republic of Cyprus with registration number HE 189107 and registered office address at 33A Okeanidos Street, 4103, Limassol, Cyprus, ("Positive", "Company", "we", "our", "us" or ourselves) with regard to and in respect of the access to and use by the persons described herein below of our platforms, websites, software and other products and services provided by or otherwise owned or controlled by Positive, in existence now or in the future, which are marketed under the brand name "Mantle" (collectively the "Service").

We collect, use, and otherwise "Personal Information" relating to natural persons, including, without limitation, personal information of users or visitors to or of our website or the Service (any such natural person, "you", "your" or "yourself") for the purposes and objects described in this Privacy Policy. We predominantly process Personal Information as a data controller but there may be circumstances where we process such information as a data processor, i.e. where your Personal Information was communicated, supplied or transmitted to us by one of our customers or partners. In the latter case, if you wish to exercise any of your rights under applicable data privacy law (as such are reproduced in this Privacy Policy) please contact the applicable customer or partner directly. At all times, we will process your Personal Information in accordance with this Privacy Policy and applicable data privacy laws and regulations.

This Privacy Policy should be considered and read in conjunction with our terms of service ("Terms of Service") and any other agreement between ourselves and yourself.

Your access, browsing and use of our websites, and access and use of the Service is subject to you accepting and fully complying with this Privacy Policy, the Terms of Service and any other agreement between ourselves and yourself. If for any reason whatsoever, you do not agree with this Privacy Policy or any part thereof, or with any policy or terms that we have in place as aforesaid, you should not and, in any event, should refrain from and cease immediately to access, browse and use the website, or access and use the Service. Please refer to the Terms of Service on how to terminate any access and use of the Service, as the case may be.

For your convenience, you may be able to access third party websites, applications or platforms through links available through the Service. Positive does not have control over those properties and does not provide any guarantee about their privacy practices. Your use of such properties will be governed by the privacy policies of those properties and not by this Privacy Policy.

Please ensure that you read, fully understand and agree with the contents of this Privacy Policy. In the event where you require any clarification or wish to exercise any of your rights (as such are referred to herein below), please use the contact details available herein to get in touch with us.

2. Collection of Information

We collect and process information, including Personal Information, only where we have a lawful basis to do so under applicable law and regulations. Lawful bases on which we may rely include, without limitation, your consent where you have given it, a situation in which processing is necessary for us to perform our obligations pursuant to a contract with you, the legitimate interests of our business, such as providing the Service to you and where it is our legal obligation to process your personal information to comply with any legal obligations imposed upon us. It may be the case that more than one legal basis may apply to your circumstances.

We collect and process a variety of personal information, including, without limitation, the following categories of information:

2.1. Information You Provide To Us

We collect Personal Information through the Service in order to facilitate and support the features of the Service. Such Personal Information may include your name, mailing and email addresses, and phone number; usernames, passwords and other credentials; payment information; areas and topics of interest; and comments and notes you post to the Service or otherwise provide to us.

2.2. Information We Receive From Third Parties

We may collect or process Personal Information we receive from third party sources such as partner organisations with whom we co-operate. Such Personal Information may include your name, mailing and email addresses, and phone number.

2.2. Information We Collected Automatically

We may automatically collect information as you use the Service, including your IP address, operating system, browser information, and other unique or technical identifiers; referring website address; date and time of your use; content you search or access; details of financial transactions you participate (or intend to participate) in on the Service, including, without limitation, the amount, currency, and method of payment and information shared with us via social media. We collect this information for the purposes set out in section 3 below, including providing the Service to you, customizing it for you, and communicating with you.

Your browser may use small data files stored in "cookies" to automatically transmit some of the foregoing information to us, such as session information used to authenticate you to the Service. We use such information to validate your authorised use of the Service, monitor traffic to the Service and better understand how you interact with the Service, with the aim of improving the Service. In general, this information is not treated as Personal Information, unless we combine it with or link it to any Personal Information. While you may be able to disable cookies or other features with your browser, doing so may affect the performance and functionality of the Service.

We use or may use the data collected through tracking technologies to, inter alia: (a) remember information so that you will not have to re-enter it during your visit or the next time you use the Service; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technical problems; and (g) otherwise to plan for and enhance the Service.

3. Processing of Personal Information

We process the Personal Information collected for the following purposes:

Providing, updating and improving the Service;
Fulfilling requests or transactions and providing user support;
Evaluating the performance of the Service;
Diagnosing and correcting technical issues or implementing preventative measures to address potential technical issues and/or faults;
Communicating with you, including, without limitation, about the Service and your subscription with us or to notify you of any prospective maintenance to the Service or disruption of the same;
Customising the Service for your subscription or to your needs or specifications;
Displaying content to you that is relevant to your location, interests and use of the Service;
Confirming legitimate subscriber activity and detecting, preventing or otherwise addressing security threats, fraud and abuse;
Analysing use and traffic trends using web analytics tools and developing new features or enhancements;
Verifying your identity;
Performing our contractual obligations towards you or the entity you represent;
Providing you with any service or fulfill any task that you request of us or of any of the third parties or partners with whom we co-operate with;
Protecting or enforcing our interests and rights;
Enforcing legal claims, including investigation of potential violations of our Terms of Serviceor abt other agreement between ourselves and yourself;
Complying with a legal obligation to which we are subject to;
Investigating or settling inquiries and/or disputes;
Enforcing our agreement(s) with you and/or the entity you represent;
Processing your payment information to execute payments or refunds and update payment information, as the case may be.

4. Retention of Personal Information

When Personal Information is no longer necessary or relevant for our purposes in the context of the service or required under applicable laws, Positive will delete or destroy the Personal Information or render it anonymous.

5. Disclosure of Personal Information

Access to the Service is provided to you by Positive. We do not disclose your Personal Information to third parties, except as stated below, or if we have your consent to do so at the time of disclosure, or as otherwise permitted or required by law. However, we may aggregate, or strip information of personally identifying characteristics, and then share that aggregated or anonymized information with third parties.

5.1. Disclosure by Law

We will disclose your Personal Information if we are required to make disclosure by law, for example, to respond to or comply with any law or court order; or to investigate and prevent security threats or fraud. We may also disclose your Personal Information if it is necessary for us to collect a debt from you or vindicate our rights under a contract with you (including our Terms of Service).

5.2. Third Party Service Providers

We may also share your Personal Information with our third party service providers in order to process information and data on the Service, process payments, provide user support service to you, and survey or assess your satisfaction with the Service. When we disclose your Personal Information to third party service providers, it is solely for the purpose of performing services on our behalf. Third party service providers are not entitled to use your Personal Information beyond the purposes for which it is disclosed to them. We do not sell or rent your Personal Information to third parties. We may work with payment processors to help process credit card transactions and other payment methods made through the Service. These payment processors will store certain information about you. Please refer to their privacy policies to learn more about how they use your Personal Information.

The Service may include access to social media applications, networks or other forums, platforms and features (the "Social Media Platforms and Features") that permit you to publish or disclose Personal Information and other content. When you use the Social Media Platforms and Features, any information you post should be considered to be public. Please make sure you trust these applications before sharing any information on them or with or through them, as we are not responsible for them. For information on how to disconnect your Service account from such applications, please see section 10 below.

5.4. Business or Asset Transfer or Sale

Positive may be sold, might sell or buy businesses or assets of businesses, or Positive might merge with another business. Normally, in the instance such transactions, user information is one of the transferred business assets. In the event that Positive, a line of business of Positive, or substantially all the assets of Positive are transferred as part of such a transaction, your information may be one of the transferred assets. Positive will make reasonable effort to provide notice on the Service and to notify you via email to the most recent email address that you have provided of any such change in ownership or control of your Personal Information. In such an event, steps will be taken to ensure that your Personal Information will continue to be protected by this Privacy Policy. Nevertheless you have the option to exercise your rights under section 10 below with regard to your Personal Information.

5.5. International Transfer

Your information may be transferred to, and maintained on, servers and computers located outside of your jurisdiction, where the privacy laws may differ from those in your jurisdiction. We are is a Cyprus-incorporated and existing company and as such, the Service is, under no circumstances, intended to be or become subject to or to subject us to the laws or jurisdiction of any state, country, or territory other than that of the Republic of Cyprus and the European Union. Nonetheless, we may transfer Personal Information throughout, and between, the Republic of Cyprus, the European Union, or other jurisdictions provided that at all times we adhere to applicable laws and regulations and process your Personal Information to a European Union standard.

6. Data Security

We are serious about our responsibility to protect your Personal Information. We take administrative, technical and physical measures to safeguard your Personal Information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access to and use of Personal Information. We take physical precautions to ensure that the servers on which your Personal Information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your Personal Information and take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and applicable law and regulations.

We take precautions against possible breaches of our security systems, and we require your cooperation in maintaining the integrity of Service accounts and restricting access by persons other than authorised users. However, no company can fully eliminate the risks of unauthorized access to Personal Information, and no website, platform or application is completely secure. We cannot guarantee that unauthorized access, hacking, data misuse or alternation or loss or breaches of our protocols, security and systems will never occur.

We encourage and expect you to take and maintain all reasonably expected measures (including, without limitation, installing and keeping up to date firewall and anti-malware systems on your device) in order to safeguard your use of the Service and information you transmit therewith or therethrough. Accordingly, you remain solely responsible for the security of your device at all times and we may not have any responsibility whatsoever for destruction or inappropriate disclosure of your Personal Information.

7. Links to Third-Party Services

For your convenience, the Service may provide links to third-party websites or services that are not governed by this Privacy Policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by us, we are not responsible for those websites' or services' content or information practices or policies. We encourage you to review the privacy policies of any such website or service before providing any personal information. By using the Service, you acknowledge anda gree that we will not be liable for any damage or loss caused by or resulting or arising from your use of or reliance on any content, advertising, products, or other materials on or available from the aforesaid third-party websites or services.

8. Minors' Privacy

The Service is not directed to natural persons under the age of 18 years ("Minors"). We do not solicit and will not knowingly collect or otherwise process Personal Information from or of Minors. If we learn that any personal information has been collected inadvertently from a Minor, we will delete the information as soon as reasonably possible. If you believe that we might have collected or processed information about a Minor, please contact us using the contact information provided in section 13 herein.

9. Changes to Policy

From time to time we may amend this Privacy Policy. We therefore urge you to frequently visit the Website in order to stay up to date with how we process your Personal Information. Where possible, we will notify you of any significant changes via an email or will otherwise bring such changes to your attention. Your continued use of the Service following the introduction and publication of any such amendments will signify your acceptance to any such changes or modifications.

10. Your Rights Regarding Your Personal Information

You have certain data protection rights under applicable laws and regulations. We aim to make it easy for you to correct, amend, delete, or limit the use of your Personal Information in relation to the Service.

10.1. Changing or Deleting Your Personal Information

You may review, update, correct, or delete any Personal Information. Please contact us using the contact information provided in section 13 herein if you would like to review or request an update, correction or other change to your Personal Information. We will respond to your request as soon as is reasonably practicable or as required by applicable law. We may take reasonable steps to verify your identity, and make a record of your communications with us. If you request us to completely delete all of the Personal Information we maintain on you, your user account may become deactivated - however, we will not be required to satisfy your foregoing request where if, inter alia, processing of your Personal Information is required for our compliance with a legal obligation that we are subject to or for the establishment, exercise or defense of legal claims. Please note that we may retain information that is otherwise deleted in anonymized or aggregated form, in archived or backup copies as required pursuant to record retention obligations or otherwise.

10.2. Objecting to Processing of Your Personal Information

If you believe that your fundamental rights and freedoms outweigh our legitimate interests, you are entitled to object to processing of your Personal Information which has our legitimate interests as its legal basis. Once you have objected, we will have the opportunity to demonstrate that we have compelling legitimate interests to continue processing your Personal Information which override your rights and freedoms.

10.3. Restricting Processing of Your Personal Information

You may request that we restrict the processing of your Personal Information in certain circumstances, such as where you contest the accuracy of that Personal Information. If you are entitled to such restriction and if we have shared your Personal Information with others, we will take steps to notify them about the restriction where it is possible for us to do so. Upon your request and where it is possible and lawful for us to do so, we will also tell you who we have shared your Personal Information with such that you can contact them directly.

10.4. Download or Accessing Personal Information

You can request a copy of your Personal Information (including in machine readable form), as well as information about its processing and storage.

You can withdraw your consent or otherwise opt out of certain features of the Service. However you should be aware that if you choose to do so there may be potential consequences which we will tell you about at such time.

10.6. Complaining to the Local Supervisory Authority

You are entitled to lodge a complaint with the local supervisory authority, which is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus in case you are not satisfied with the manner in which we process your Personal Information.

11. Marketing Communication

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Service features, products, events, or other opportunities relating to your engagement of the Service.

Where we have your consent to do so (i.e. if you have subscribed to our newsletter or have consented that you would like to hear about our offers, courses, services, news or publications), we will periodically send you marketing communications via email in relation to such items that we believe may be of interest to you.

If you wish to stop receiving communications such as the foregoing or to opt out of use of your information for these purposes, please follow the opt-out instructions by clicking "Unsubscribe" (or similar opt-out language) in those communications. Alternatively you may request that you stop receiving those communications using the contact information provided in section 13 herein.

Once you have unsubscribed as aforesaid, we will remove you from our marketing and other relevant mailing lists.

12. Do Not Track Feature

Some browsers, Apps and devices support a "Do Not Track" feature. The Services does not currently change the way it operates based upon detection of a "Do Not Track" or similar signal.

13. Contact Information

If you have any questions about the Privacy Policy or wish to exercise your rights with respect to your Personal Information, please contact the Company using the following contact details.

Postal address: 33A Okeanidos Street, 4103, Limassol, Cyprus
Telephone number: +357 25 870087
Facsimile number: +357 25 870086
Email address: [email protected]