Privacy Notice

On our website (scm.global, hereinafter referred to as the “Site”), you do not have to give your personal data, but you can indicate them for the purposes described below. We can also receive your personal data automatically according to procedures described below.

We recognise that your privacy and personal data protection are important and undertake to process and store data responsibly according to the European General Data Protection Regulation ("GDPR").

This Privacy Policy ("Policy") describes the types of information we collect on this Site, including personally identified or identifiable information ("personal data"), purposes for which we use such personal data, with whom we may share the information, the rights and choices available to you regarding our use of your personal data. This Policy also describes how you can contact us about our privacy practices.

Please read this Policy before using or submitting any personal data on the Site.

By visiting and using this website, you acknowledge that you have read and accept the information herein and understand how we collect, process, use and disclose your personal data.

1. PURPOSE AND SCOPE

1.1. SCM (SYSTEM CAPITAL MANAGEMENT) LIMITED (hereinafter referred to as “SCM Limited” or “we” or “us”) is constituted under the laws of Cyprus, with its seat at 226 Arch. Makariou III Avenue, 3rd floor, 3030, Limassol, Cyprus.

1.2. SCM Limited acts, in relation to the processing operations mentioned in this notice, as a “data controller” in the meaning of the European General Data Protection Regulation.
In case when you are reporting an incident connected with activities of the SCM Business, the respective company of the SCM Business will act as a “data controller” and we will act as a “data processor”.

1.3. In such a context, SCM Limited is committed to protecting your privacy. This Privacy Notice addresses how SCM Limited processes and safeguards your personal data as a data controller, when you are interacting with us, in particular by visiting our website or contacting us.

1.4. For any question or concern regarding this Privacy Notice, you can directly contact:
SCM (SYSTEM CAPITAL MANAGEMENT) LIMITED 226 Arch. Makariou III Avenue, 3rd floor, 3030, Limassol, Cyprus.

2. WHAT DATA WE COLLECT

2.1. SCM Limited applies the minimization principle and only processes the personal data that is required for the purposes pursued.

2.2. Name and e-mail address

Source of origin: The Website has a feedback form where you can enter your name and e-mail address. When you fill in the form, this data will be stored and can be used to provide you with the requested information or to communicate with you.

Time of storage: Your name and e-mail address is stored in the system for 36 months after you have filled in the form.

Legal basis: The legal basis for this processing of your name and e-mail address is your consent provided by checking the appropriate box on the form.

Right to withdraw consent: You may withdraw your consent for the storage and use of your e-mail address for the purposes described above at any time by sending a request to the following e-mail address: pd@scm.com.cy. If you do so, your e-mail address will be deleted and we will no longer be able to contact you using that e-mail address.

2.3. Other data collected on the basis of legitimate interest

Based on our legitimate interests, we collect the following data for the purpose of running this website. Your data is not used for any other purposes or shared with third parties. It is removed upon your request.

2.4.1. Automatically collected data

Source of origin: Each time you visit the Site, the system automatically collects information about the device the visitor uses to view pages, such as:

browser type and version;
operating system;
IP address.

Time of storage: this data is collected and temporarily stored for the purpose of correct display of the Site content on the user's computer. The data will be deleted as soon as it is no longer necessary to use it - at the end of the session (when the user leaves the Website).

We do not match the data automatically collected by the information system with other personal data of natural persons.

2.4.2. Cookies

We use cookies for the following purposes:

to make the Site more user-friendly; to personalize the content or settings of the Site; and
to anonymously collect statistical information. (We may use statistical information to improve existing Site services and develop new Site services).

Cookies are also necessary for certain features of the Site to work properly, such as to save your session when you navigate through pages.

Source of origin: cookie is a file stored on the hard disk of the user's personal computer when the user visits the pages of the Website. Such file contains a set of characters that allow us to identify the user's device or browser when you revisit the Website.

Time of storage: cookies processed will be deleted or anonymized when the specified processing purposes have been achieved or if there is no further need to achieve these purposes. You can limit the use of cookies in your browser settings.

Please note that if you change your browser settings, the functionality of the Site may be limited and some content may not display correctly.

Legal basis: the legal basis for this processing of your personal data collected through cookies is the need to fulfill the legitimate interests of SCM Limited and third parties, including maintaining our Site and improving or developing our business; or

• your consent (given by clicking ["Continue"/"OK"/...] on the cookie banner on the Site)

Right to withdraw consent: you will be able to withdraw your consent and change your choices at any time through your browser settings.

2.4.3. Statistics

The website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States and allows us to notice trends to improve the user experience on our website. Google Analytics may use cookies to:

identify unique users;
limit the frequency of requests;
remember the number and time of previous visits; record the source of traffic;
determine the start and end of a session; and
remember the values of user-declared variables to determine the level of the visitor.

Information about your device (browser and its version, operating system) with which you browse the pages of the Site may be sent to Google Analytics.

Time of storage: We use the data in Google Analytics for statistical purposes and store it for a maximum of 26 months.

Right to withdraw consent: You may opt out of this tracking at any time by activating the “Do Not Track” setting in your browser.

3. HOW WE PROTECT YOUR DATA

3.1. All our systems are built with strong security features aimed to protect your information. We use numerous hardware and software solutions and physical security measures, to prevent unauthorized access to our systems.

3.2. In addition, we restrict access to personal information to our employees and contractors, who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

4. YOUR RIGHTS PERTAINING YOUR DATA

4.1. Under personal data protection legislation, you are entitled to rights of which you should be aware:

The right to withdraw consent
The right of access
The right to erasure
The right to rectification
The right to data portability
The right to object
Notification of data breaches
The right to lodge a complaint with a supervisory authority

4.2. Requests regarding the protection and processing of personal data:

If you have left your information on the Website, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we rectify or erase any personal data we hold about you. Whenever the processing activity is based on your consent, you may at any time withdraw it.

Please send your request to pd@scm.com.cy