Terms and Definitions
For the purposes of applying and interpreting this Policy, the key terms defined below are used
(unless the Policy expressly states otherwise).
Policy – this G-GATE Privacy Policy presented below in its full entirety.
Administration – a company that owns and operates this site and handles the processing of the
personal data in accordance with this Policy.
Data confidentiality – a mandatory requirement for all parties, including the Administration
or persons authorized by it who have gained access to data, to prevent their disclosure or
distribution without the consent of their owner or other legal grounds.
Personal data information system – a set of personal data contained in databases and
information technologies and technical means that ensure their processing.
Processing of personal data – an action or a set of actions with personal data described in
this Policy.
Automated processing of personal data – processing of personal data using computer technology.
PD – any information relating to a directly or indirectly identified or identifiable natural
person (subject of personal data), including but not limited to: Name and Surname, Date of Birth,
Address of registration, ID/Passport Details, Age, Sex, Email, Phone number, Contacts in Social
Networks and Messengers, Marital status, Nationality, Political views, Religious and Philosophical
beliefs, Health status, Occupation details.
User Agreement – an agreement concluded between the Administration and the User regarding the
terms of use of the site.
User – an individual who is a party to the User Agreement with the Administration and uses
this site.
Providing personal data – actions aimed at disclosing personal data to a certain person or a
certain circle of persons.
Applicable law – the law of the Republic of Cyprus and the law of European Union (in
particular, General Data Protection Regulation (GDPR)) where it is applicable.
Distribution of personal data – actions aimed at disclosing personal data to an indefinite
circle of persons.
Collection of personal data – a purposeful process of obtaining personal data by the
Administration directly from Users.
The subject of personal data – the natural person to whom the personal data relates.
Cookies – small pieces of data sent from the site and stored by the browser on the user’s
device, which are used to remember information, preferences and settings of the User when using the
site. Cookie technology is used to improve the individual experience and convenience when working
with the site and using all its functions and elements.
Blocking of personal data – a temporary suspension of the processing of personal data (unless
the processing is necessary to clarify personal data).
Website – a set of graphic and informational materials, as well as computer programs and
databases that ensure their availability on the Internet.
Personal data operator – a state body, municipal body, legal entity or individual,
independently or jointly with other persons organizing and (or) carrying out the processing of
personal data, as well as determining the purposes of processing personal data, the composition of
personal data to be processed, actions (operations) committed with personal data.
Destruction of personal data – any actions as a result of which personal data is irretrievably
destroyed with the impossibility of further restoration of the content of personal data in the
information system of personal data and (or) material carriers of personal data are destroyed.
1. General Provisions
1.1. This Policy establishes the rules for ensuring confidentiality and the procedure for processing
personal data (PD) of PD subjects (hereinafter also referred to as «Users») and cookies by the
Administration when visiting and using the site by the User in accordance with the terms of the User
Agreement, as well as performing other actions provided for User agreement.
1.2. This Policy contains information on the basic principles, purposes, procedure and conditions for
processing PD and cookies by Administration, as well as information on the requirements implemented
by the Administration for the protection of processed data, and is designed to ensure the protection
of the rights and freedoms of PD subjects when processing their PD by the Administration.
1.3. The current version of this Policy is constantly published on the website in order to ensure
constant and unlimited access to it.
1.4. This Policy has been developed in accordance with Applicable Law.
1.5. The user, by carrying out the actions provided for by the functionality of the site, confirms
that he has read this Policy, agrees to the terms of processing PD and cookies, and has agreed to
the processing and collection of PD and cookies indefinitely.
2. Basic conditions for processing PD
2.1. The processing of PD by the Administration is carried out on the basis of the following principles:
processing of PD is carried out by the Administration on a legal basis;
PD processing is limited to the achievement of specific, predetermined and legitimate purposes;
processing of PD that is incompatible with the purposes of collecting PD is not allowed;
it is not allowed to combine databases containing PD, the processing of which is carried out for
purposes that are incompatible with each other;
only PD that meet the purposes of their processing are subject to processing;
the content and volume of the processed PD corresponds to the stated purposes of processing;
when processing PD, the accuracy of PD, their sufficiency, and, if necessary, relevance in relation to
the purposes of processing PD, are ensured.
PD is stored in a form that makes it possible to identify the PD subject, no longer than required by the
purposes of PD processing, unless a different period of PD storage is established by an agreement to
which the PD subject is a party, beneficiary or guarantor. The processed PD is destroyed upon reaching
the purposes of processing or in case of no longer being necessary to achieve these purposes, unless
otherwise provided by law.
2.2. The Administration does not collect and process personal data of subjects containing information
about Race, ID/Passport details, Sex, Nationality, Criminal Record, Political Views, Religious and
Philosophical beliefs, Health status, Marital status.
2.3. The transfer (exchange, etc.) of PD is carried out on the basis of the consent of the subject of
the PD, including in the form of expressing consent through the functionality of the site.
2.4. The PD of the subject can be provided to other persons only with the written permission of the
subject of the PD, except in cases where the PD is provided to the Users of the subjects of the PD using
the site or when the transfer of PD without the consent of the subject is allowed by the European
Union’s General Data Protection Regulation (GDPR).
3. Categories and purposes of their data processing
3.1. PD and cookies may be processed through the website for the following purposes:
implementation and maintenance of communication between the Administration and the User as a supposed
lead;
sending messages necessary for the use of the site and notifications of a technical nature;
use of the site;
implementation by the User of actions to fulfill its obligations in accordance with the User Agreement;
3.2. The Administration does not verify the accuracy of the information provided by the User, as well as
the User’s legal capacity.
3.3. The Administration never collects PD and cookies in secret from the Users. The site may use tools
for maintaining statistics of User visits and other similar tools that collect and analyze only
depersonalized information that is not PD.
3.4. The Site can automatically save on the User’s device cookies that do not contain PD and are not
used to identify the User.
3.5. The Administration does not collect or process cookies about the behavior and activity of the User
outside of this site.
3.6. Refusal to grant the right to collect and process cookies is possible, but this may lead to the
impossibility or significant difficulties in using the site.
4. Composition and legal grounds for the processing of PD and cookies
4.1. Source of PD reception, collecting and processing: PD subject.
4.2. The composition of the processed PD:
Name and Surname of the User;
E-mail address of the User;
Phone Number of the User;
User’s Telegram Messenger Contact;
User’s occupation details (if necessary);
User’s location (geoposition) (if necessary).
The above data will be recognized as PD if it is possible to identify the subject of the PD through
comparison and combination with other data about the User. Otherwise, the specified data will only be
recognized as cookies.
4.3. The Administration uses the following types of cookies in the operation of the site:
Functional cookies used to remember personal information, individual settings and preferences of users,
to improve individual experience, improve quality and simplify the work of the site;
Advertising cookies used to collect information about site visits, interests, content viewed, links
opened, for the purpose of targeting to send personalized advertising to users;
Analytical and performance cookies used to recognize and count the number of users, collect statistics
about the use of the site, to improve the quality of our services, products and services;
Session cookies, used temporarily while you are on the site and deleted when you close your browser and
exit the site.
5. Procedure and conditions for processing PD and cookies
5.1. The processing of PD and cookies on the site is carried out in ways using automation tools for the
periods necessary to achieve the goals of processing. The condition for terminating the processing of PD
and cookies by the Administration may be the withdrawal of the User’s consent to the processing of his
PD and cookies, which can also be transferred to the Administration through the company that provided
access to the site.
5.2. Using the functionality of the site, the Administration collects, records, extracts and uses the
Users’ PD and cookies.
5.3. To achieve the stated processing goals, the Administration may distribute PD and cookies to third
parties, including its affiliated companies, as well as entrust the collection and processing of PD and
cookies to other persons or legal entities on the basis of an agreement containing confidentiality terms
and other mandatory provisions prescribed Applicable Law. Third parties have the right to communicate
with Users, as well as send any information and advertising materials related to the activities of the
Administration.
5.4. When collecting PD, the Administration always assumes that the User provided reliable and
up-to-date PD. The Administration may contact the company that provided the User’s access to the site in
order to request clarification of the User’s PD in case of revealing unreliable or inaccurate data.
5.5. The Administration guarantees that the information provided by the User is not provided to third
parties and is not disclosed, except as provided in the Policy.
5.6. The Administration uses cookie technology and other identical technologies in order to:
Provide site navigation;
Generate the summary statistics about the use of the site;
Provide the ability to share content with others;
Improve the User’s experience of using the site and digital services;
Conduct analytics and data research to improve the quality of services, services and products on the
site;
Store individual settings and personal preferences to improve the convenience and experience of using
the site;
Conduct error management and troubleshooting to ensure the functionality and optimal operation of the
site.
6. Rights of the parties
6.1. The user has the right to:
obtain information from Administration regarding the processing of his PD and cookies, including access
to his personal data and obtaining a copy of any record containing his PD, except as required by law;
clarify his/her PD, his/her blocking or destruction in cases established by law through the company
providing access to the site, if there is such a technical possibility.
appeal against actions (inaction) of the Administration in the competent authorities;
protect his/her rights and legitimate interests;
withdraw the consent to the processing of PD and cookies, as well as communication;
exercise other rights provided for by law.
6.2. The Administration has the right:
conduct statistical and other research based on depersonalized information provided by the User;
transfer, disclose, exchange PD, anonymized information and cookies to any third parties for free use,
as well as to detect and stop fraudulent activities, to eliminate technical problems or security
problems.
7. Update, correction, deletion and destruction of PD
7.1. In case of confirmation of the fact of inaccuracy of PD or illegality of their processing, PD can
be updated by the Administration, or their processing is terminated by the Administration.
7.2. Upon reaching the goals of processing PD, as well as in the event that the subject of PD withdraws
consent to their processing, PD is subject to destruction, except as otherwise provided by the
Applicable Law. When withdrawing consent to the processing of cookies, the Administration stops any
collection of such data and actions that can be carried out using cookies.
8. Limitation of Liability
8.1. The site is not a public source of personal data. At the same time, if the User performs certain
actions, his personal data may become available to an indefinite circle of persons, about which the User
hereby gives his consent.
8.2. The user agrees to receive informational messages necessary for the functioning of the site and
notifications of a technical and (or) advertising nature.
8.3. The Administration informs the site Users that this Policy applies only to the site.
9. Final provisions
9.1. This Policy comes into force from the moment of approval, is put into effect by order of the
Administration and is valid indefinitely (until it is canceled or replaced by a new version of the
Policy)
9.2. The requirements of this Policy apply to all employees of the Administration who have access to
personal data, as well as to all site Users.
9.3. The Administration has the right to unilaterally make changes and (or) additions to this Policy.
The new version of the Policy comes into force from the moment of its publication (posting) on the
website, unless otherwise provided by the new version of the Policy. In the event of changes affecting
the rights of the Users, the Administration has the right to send information about these changes to the
Users using their contact details or notify them of the changes in another way.
9.4. In the event of a dispute related to the application or compliance with this Policy, the
Administration and the relevant User will make every effort to resolve it through negotiations and (or)
mutual compromises. If the conflict is not resolved through negotiations and (or) mutual compromises,
the dispute is subject to resolution in the manner prescribed by applicable law.