Privacy Policy

This Privacy Policy explains how ETM Marketing Ltd (“we”, “us”) processes personal data when you visit etmhq.com, contact us, or work with us as a business client. We process personal data in line with the EU General Data Protection Regulation (GDPR) and the applicable law of the Republic of Cyprus.

1. Who is responsible

The controller of your personal data is ETM MARKETING LTD, a company registered in Cyprus under registration number HE 498361, with its registered office at Efesou 9, Paralimni 5280, Famagusta, Cyprus. You can contact us about privacy at info@etmhq.com.

2. What data we process

• When you email us: your name, email address, company name and anything you include in your message.
• When you are a client or work for one: business contact details of the people we deal with, and the information needed to deliver our services and to invoice.
• When you visit this website: our hosting provider automatically records technical data such as your IP address, browser type and the pages requested, in server logs needed to deliver and secure the website.

This website does not use cookies, analytics, tracking pixels or contact forms.

3. Why we process it and on what legal basis

• To respond to your enquiry and to prepare an agreement: steps prior to entering into a contract, or our legitimate interest in answering business enquiries (Article 6(1)(b) and (f) GDPR).
• To deliver our services and manage the client relationship: performance of a contract (Article 6(1)(b) GDPR).
• To keep accounting and tax records: compliance with a legal obligation (Article 6(1)(c) GDPR).
• To operate and secure this website: our legitimate interest in a working, secure website (Article 6(1)(f) GDPR).

4. Who we share it with

We do not sell personal data. We share it only with service providers who help us run our business, such as our website hosting provider, email provider, accountants and auditors, and with authorities where the law requires it. Our service providers process personal data on our instructions and under appropriate data processing terms.

5. Transfers outside the EEA

Some of our service providers may process data outside the European Economic Area. Where that happens, we rely on an adequacy decision of the European Commission or on the Commission’s Standard Contractual Clauses to protect your data.

6. How long we keep it

• Enquiries that do not lead to an engagement: up to 12 months.
• Client and contract records: for the duration of the relationship and afterwards as long as required by Cypriot accounting and tax law.
• Server logs: kept by our hosting provider for a short period, in line with its own retention policy.

7. Your rights

Under the GDPR you have the right to access your personal data, to have it corrected or erased, to restrict or object to its processing, and to data portability. Where processing is based on our legitimate interest, you can object at any time. To exercise any of these rights, email info@etmhq.com.

You also have the right to lodge a complaint with a supervisory authority. In Cyprus this is the Office of the Commissioner for Personal Data Protection (www.dataprotection.gov.cy).

8. Security

We take appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. This website is served over an encrypted connection (HTTPS).

9. Changes to this policy

We may update this Privacy Policy from time to time. The current version is always published on this page, with the date of the last update at the top.