Privacy Policy

Notification concerning the Processing of Personal Data

Introduction

We would like to assure you that for Superbo Ltd (the “Company”), the protection of the personal data of its shareholders and investors and any other case where there is identification of natural persons and users of our website is of paramount importance. That is why we are taking appropriate steps to protect the personal data we process and to ensure that the processing of personal data is always carried out in accordance with the obligations laid down by the legal framework by the company itself.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.

Controller – Data Protection Officer (DPO)

Superbo Ltd, headquartered in 145 Queen’s Road East, Wan Chai, Hong Kong with e-mail: [email protected], tel. no: +306937093160, informs you for the purposes of its business activities. For any matter concerning the processing of personal data, please contact us via e-mail at [email protected] or via letter sent to the above postal address of Superbo Ltd.

What data is collected?

The only data gathered in the website is the name, email address and any other information the website user wishes to share with us for composing queries to us. In addition there is data which is automatically collected by the system such as IP address, device type, browser type, pages of this website visited, the date and time of your visit.

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone or post) about developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal data for promotional purposes (see later ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell OR share it with other organizations for marketing purposes. You have the right to opt out of receiving promotional communications at any time by contacting us in writing as stated above.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

 

Cookies

Cookies are small text files that are stored on your computer or mobile device when you visit a website. We use the term “cookies” as a global term to describe techniques such as cookies, Flash cookies and web beacons. Cookies are primarily used to make sure that your visit to our websites is as user-friendly as possible. You have the option to consent or not when you first visit our site for the use of cookies.

Age of website users

The Company and its web sites are addressed to persons who have reached the age of 18. If minor users voluntarily visit our sites, the Company has no responsibility. In the event that when the data is collected it becomes clear that the user is younger, the Company will not process his / her personal data.

What are the legitimate reasons for processing your personal data?

We only process the personal data you provide us for the provision of information when questions or comments are submitted through the website form, in the context of an existing contract or pre-contractually, so that measures may be taken at the request of the subject.

How and why do we use your personal data?

To communicate with you and manage our relationship with you. We may need to contact you by e-mail or telephone for administrative purposes, such as through the contact form found on our website, in order to respond to a question or comment you made.

Where are your data shared?

Your data is only shared among the responding members of our group who are required to respond to your queries through the website form.

Data Storage Period

The length of the data storage period is decided on the basis of the following specific criteria, as appropriate:
When processing is done on a contractual basis, your personal data will be stored for as long as is necessary for the performance of the contract and for the foundation, exercise, and/or support of legal claims under the contract.
When processing is required as an obligation under provisions of the legal framework in force, your personal data will be stored for as long as required by the relevant provisions.

What are your rights with respect to your personal data?

Right to access:

You have the right to be made aware and verify the legitimacy of the processing. Thus, you have the right to access the data and receive additional information concerning its processing.

Right to rectification:

You have the right to study, rectify, update or modify your personal data by sending an e-mail to [email protected] or a letter to the postal address of the Company.

Right to erasure:

You have the right to request the erasure of your personal data when we process it or in order to protect our legitimate interests. In all other cases (for example, where there is a contract, an obligation to process personal data required by law, public interest), this right is subject to specific restrictions or does not exist, as the case may be.

Right to restriction of processing:

You have the right to request a restriction on the processing of your personal data in the following cases: (a) when you contest the accuracy of the personal data and until verification takes place; (b) when you oppose the erasure of personal data and request the restriction of their use instead of erasure; (c) when the personal data are not needed for processing purposes but are necessary for the foundation, exercise and support of legal claims; and (d) when you object to the processing and it is verified that there are legitimate reasons that concern us and supersede the reasons for which you oppose the processing.

Right to oppose processing:

You have the right to object at any time to the processing of your personal data where, as described above, it is necessary for the purposes of the legitimate interests we pursue as controllers, as well as for processing for direct marketing and consumer profiling purposes.

Right to portability:

You have the right to receive your personal data free of charge in a format that allows you to access, use, and edit them through commonly used editing methods. You also have the right to ask us, if technically feasible, to transfer the data directly to a different controller. Your right to do so applies to the data that you have provided to us and that is being processed by automated means based on your consent or performance of a relevant contract.
In order to exercise any of the above rights, please contact us via e-mail at [email protected] or via letter sent to the above postal address of the Company

Right to complain to the HDPA

You have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr): Call Centre: +30 210 6475600, Fax: +30 210 6475628, E-mail: [email protected]

Personal Data Security

The Company applies appropriate technical and organisational measures to secure the processing of personal data and to prevent the accidental loss or destruction and unauthorized and/or unlawful access to, use, modification or disclosure of personal data. In any event, the manner in which the Internet functions and the fact that it is freely accessible by anyone cannot guarantee that unauthorised third parties will never be able to violate the technical and organisational measures applied, gaining access and potentially using personal data for unauthorised and/or illicit purposes.

Changes to this privacy policy

This privacy policy was published on the 30th of April 2023. The privacy policy will be reviewed on a yearly basis and any amended version will be immediately uploaded to our website.

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