Last Update: March 2019
1. Introduction
1.1. ANTENNA LIMITED is dedicated to protecting your privacy and the confidentiality of the personal information entrusted to us. We process your personal information in accordance with the applicable legal and regulatory framework, including the Law on the Protection of Natural Persons Against Personal Data Processing and the Free Movement of Such Data of 2018 (L. 125(I)/2018) and the General Data Protection Regulation 2016/679 (the “GDPR”), as they are amended from time to time.
1.2. This present notice (the “Online Privacy & Cookies Policy”) is directed to the users of and/or visitors to our websites, applications, and other online and/or digital platforms and services, such as the ant1.com.cy webpage and application, the Ant1radio webpage and application, the Premium Web TV service, the Facebook Messenger Bot service, our YouTube channel(s) and social media accounts on Facebook, Instagram, Twitter and Viber (the "online products and services"). Information about our online products and services is available at http://www.ant1.com.cy/about/parousiasi-tou-ant1/.
1.3. This Online Privacy & Cookies Policy provides an overview of how and why we collect, use, store, disclose and protect the personal information of the users of and/or visitors to our online products and services, how we use cookies, as well as of the rights of such individuals under the GDPR. Please read the following carefully in order to understand our policies and practices regarding your personal data and how we process them.
1.4. For the purposes of the present Online Privacy & Cookies Policy:
"We", "us" and "our" refer to ANTENNA LIMITED, that, for the purposes of personal data processing in respect of the said online products and services, acts as the data controller (namely, as the entity that, alone or jointly with others, determines the purposes and means of personal data processing). For more information about us, please see Section 14.
The terms “personal data”, “data” and “personal information” are used to refer to any information relating to you, as a user of and/or visitor to our online products and services, which identifies or may identify you, either directly or indirectly, such as your name and contact details.
The term “processing” is used herein to collectively refer to actions such as the collection, retention, storage, use, disclosure, transfer, deletion or destruction of personal data.
1.5. Our products and services may include links to other websites and online services that are maintained and provided by other companies. These companies have their own privacy and cookie policies and we are not responsible for how such companies use your personal data. If you are interested in learning how your personal information is processed by such companies, please refer to their respective privacy policies and/or notices.
2. How we process your personal data
2.1. In this Section we have set out:
the general categories of personal data that we may process;
the main purposes for which we may process personal data; and
the main legal bases of the processing.
2.2. We may process data about your use of and/or visit to our online products and services (the "usage data"). The usage data may include your IP address, geographical location, device and browser type and version, operating system, referral source, length of visit, page views and websites navigation paths, as well as information about the timing, frequency and pattern of your service use and/or other information collected through the use of cookies (as described in Sections 9-12 herein below). The sources of the usage data are web analytics companies (namely, Google Analytics and MaxMind GeoIP). This usage data may be anonymised (i.e. any personally identifiable information is removed, so that the data can no longer be associated with you) and/or used in aggregated form and/or as statistics, for the purposes of analysing the use of and/or visit to our online products and services. The legal basis for this processing is your consent and/or our legitimate interests (i.e. monitoring the use of and improving our online products and services).
2.3. Where you subscribe to our newsletter service, we will process your email address, as this is provided to us by you, in order to be able to deliver our newsletters; we will afterwards keep the traffic data related to the provision of newsletters (the “newsletter data”). The legal basis of such processing is your consent and/or our legitimate interests (i.e. provision of the newsletter service, promotion of our online products and services).
2.4. Where you subscribe and/or register to our online products and services, we will process the information that you give to us during the registration and/or subscription stage (e.g. your name and email address) and other information generated by the use of such an account (e.g. your preferences) (the "account data"). The source of such data is you. The account data may be processed for the purposes of operating, administering and providing our online products and services; implementing and monitoring the performance of our policies, terms and conditions regarding the use of such services and products, ensuring their security; maintaining back-ups of our databases; and communicating with you, where necessary. The legal basis for this processing is your consent and/or our legitimate interests (as described in this sub-Section above).
2.5. We may process the information included in your personal profile that you use in relation to our online products and services, such as your Facebook profile when using our Facebook Messenger Bot service (the "profile data"). The profile data may include but not limited to your name, contact details, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details and other information that you make available to the public. The profile data may be processed for the purposes of operating, administering and providing our online products and services; implementing and monitoring the performance of our policies, terms and conditions regarding the use of such services and products; ensuring their security; and communicating with you, including for the purposes of responding to your requests. The legal basis for this processing is you consent and/or our legitimate interests (as described in this sub-Section above).
2.6. Where you subscribe and/or register to receive notifications of the most important news through our iOS or Android and/or Facebook Messenger Bot service, we will process the information that you give to us during the registration and/or subscription stage (e.g. your name) and other information generated by the use of such an account (e.g. your use of and interactions with the said applications). Additionally, we will collect information about your preferences, when you subscribe to receive notifications about particular issues (as these are specified by you), through our Facebook Messenger Bot service (the “notification data”). The legal basis of such processing is your consent and/or our legitimate interests (i.e. provision of the said applications, promotion of our online products and services).
2.7. We may process any information that you post for publication on our online products and services (the "publication data"). The publication data may be processed for the purposes of enabling such publication and administering our online products and services, as well as for implementing and monitoring the performance of our policies, terms and conditions regarding the use of such services and products; ensuring their security; and communicating with you, including for the purposes of responding to your requests. The legal basis for this processing is consent and/or our legitimate interests (i.e. the provision and administration of our online products and services).
2.8. We may process personal information contained in any enquiry, request, complaint, comment and/or suggestion you submit to us regarding our online products and services, as well as your name, contact details, time of contacting us and other information associated with such communications with us (the "correspondence data"). The correspondence data may be processed for the purposes of assessing and/or investigating the matter you contact us about; responding to you; operating, administering and providing our online products and services; and implementing and monitoring the performance of our policies, terms and conditions regarding the use of such services and products. The legal basis for this processing is consent and/or our legitimate interests (as described in this sub-Section above).
2.9. Where you enter a competition through our website, we will collect your name, contact details and any other information you may provide to us (the “competition data”). Such data will be used to process your competition entry and to notify you in the event that you win one of the prizes offered. The legal basis for this processing is our legitimate interests and contract (i.e. the provision and administration of our competitions).
2.10. In relation to your personal information collected and used via cookies, please see Sections 6-9 herein below.
2.11. Please do not supply any other person's personal data to us, unless we prompt you to do so (having established that we have a lawful basis for such a request).
3. Lawful basis for processing your personal data
3.1. We only process your personal information where we have a valid reason for doing so, in line with the applicable personal data legal framework (“lawful basis for processing”).
3.2. We rely on one or more of the following lawful bases for processing your personal data in the course of the provision of our online products and services:
Contract:
We will process your personal data in order to perform the relevant contract (e.g. regarding competitions), or to take steps, at your request, prior to you entering into the said contract with us.
Consent:
We may rely on your consent at the time you provide your personal data to us (i.e. where specified in Section 2 above), or where we ask your permission to do something and you give us such permission.
Legal obligations:
We may process your personal data in order to meet our legal obligations (e.g. where we are legally required to provide them to a court of law, the police, or other public authority).
Legitimate interests:
We may process your personal data where it is necessary for safeguarding and pursuing our own legitimate interests or those of others, based on our evaluation that the processing is fair, reasonable and balanced. In addition to the legitimate interests specified in Section 2 herein above, we may process your personal information under this ground, where and when required, for reasons such as the following:
- Delivering our online products and services;
- Reviewing, developing and further improving our products and services;
- Ensuring the smooth operation and security of our network and IT operations and security;
- Responding to any enquiries, requests, complaints, comments and/or suggestions you submit to us, or to settle any disputes between you and us;
- Measures and processes for IP rights protection and theft prevention;
- Obtaining and/or maintaining insurance coverage;
-Managing business risks;
- Delivering timely market insights and speciality knowledge we believe is welcomed by our business partners;
- Establishing, pursuing and/or defending claims in judicial and/or regulatory procedures, whether in court proceedings or in an administrative or out-of-court procedure;
- Consulting with and exchanging data with external professional advisors and/or representatives (e.g. lawyers);
- Performance of our policies and procedures;
- Crimes and fraud prevention and investigation.
4. Providing your personal data to others
Where and to the extent necessary, we may share your personal information with a variety of third parties, such as the following:
Third parties that help us deliver our online products and services or act on our behalf, for example, the following:
- Insight analytics service providers (e.g. Google Analytics);
- Companies providing interest-based advertisements on our websites (e.g. Project Agora, Google Doubleclick, WisePops) and other marketing service providers;
- Mailroom support service providers (e.g. Mailchimp for the provision of our newsletters service and competitions platform);
- External IT system support service providers.
Professional advisers, including external business advisers and lawyers..
Insurers.
Law enforcement (e.g. courts, police) or other public and supervisory authorities and/or bodies or other persons as required by, and in accordance with, the applicable legal framework.
Third parties in order to participate in, or be the subject of, of any actual or potential restructure, joint venture, sale, transfer, assignment, or merger/acquisition of part of or all of our business or assets or any associated rights or interests.
5. International transfers of your personal data
5.1. In this Section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (the "EEA").
5.2. It is firstly noted that the hosting facilities for our online products and services, as well of our servers are situated in Cyprus. In regards to online video delivery, ant1.com.cy communicates automatically with a CDN (Content Delivery Network), which ensures reliable provision of content towards the user. The CDN is LogosNet, a company situated in Cyprus. Both ant1.com.cy and LogosNet process the IP of the user and share a secure access token, forbidding copyright infringement by bad actors. For the best performance of the Content-Delivery-Network, your data (IP address, Access token cookie) may be transferred outside the EEA, especially if you are residing in countries that it might be more beneficial for you to access content from a server that is nearer to your location.
5.3. We collaborate with other companies working with us or on our behalf, which may be situated in non-EEA countries, for the purposes described in the present Online Privacy & Cookies Policy. The areas where such companies are located will vary from time to time, but may include the United States (e.g. Google, for the purposes described in sub-Section 2.2. above). Where we transfer your personal information to such companies, we ensure that appropriate safeguards are in place to protect your privacy and safeguard your personal data, in accordance with the applicable personal data legal framework. For more information about transfers to non-EEA countries, please contact us at [email protected].
5.4. Only personal data that you submit for publication through our online products and services may be available, via the internet, around the world. You acknowledge that once such data are published, we cannot prevent their use or misuse by others.
6. About cookies
6.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
6.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
6.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
7. Reasons for the use of cookies
Our online products and services may use cookies for the following purposes:
authentication - we use cookies to identify you when you visit our websites and as you navigate our websites, cookies used for this purpose are provided by Google Analytics, Facebook Cookie;
status - we use cookies to help us to determine if you are logged into our websites, cookies used for this purpose are provided by InPlayer;
security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our online products and services generally. Cookies used for this purpose are provided by InPlayer and Video Streaming Secure Token;
advertising - we may use cookies to help us to display advertisements that will be relevant to you, cookies used for this purpose are provided by Project Agora, Google Doubleclick, and WisePops;
cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally; cookies used for this purpose are provided by WisePops.
8. More information about the cookies used by our service providers
8.1. Our service providers use cookies and those cookies may be stored on your computer when you visit our online products and services.
8.2. We use Google Analytics to analyse the use of our online products and services. Google Analytics gathers information about use by means of cookies. The information gathered relating to our online products and services is used to create reports about their use and/or visit. Google's privacy policy is available at: https://www.google.com/policies/privacy/ .
8.3. We may publish Google AdSense interest-based advertisements on our websites. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our websites and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com . You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org . However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
8.4. We publish Project Agora interest-based advertisements on our online products and services. These are tailored by Project Agora to reflect your interests. To determine your interests, Project Agora will track your behaviour on our online products and services and on other websites across the web using cookies. This behaviour tracking allows Project Agora to tailor the advertisements that you see on other websites to reflect your interests.
9. Managing cookies
9.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via the support service and/or privacy policy of the browser(s) that you use.
9.2. If you block cookies, you may not be able to use all the features on our online products and services. Blocking all cookies may have a negative impact upon the usability of many of our online products and services.
10. Children
We understand the importance of protecting children's privacy, especially in an online environment. In particular, our online products and services are not intentionally designed for or directed at children under the age of 14. Children under the age of 14 may only use of online products and services with the consent and/or authorisation of their parents or legal guardians. It is our policy never to knowingly collect or maintain information about anyone under the age of 14, but if it is necessary to do so, for example on the specific request of their parents or legal guardians, we will comply with industry guidelines and applicable laws.
11. Retaining and deleting personal data
11.1. This Section gives an overview of our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
11.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
11.3. We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, as described in this Online Privacy & Cookies Policy.
11.4. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example:
In relation with our applications (i.e. the ant1.com.cy and Ant1 Radio applications) we will retain data provided by the users of those applications for as long as they use the application(s) and for a reasonable time thereafter. We will retain information that is automatically collected via the use of the said applications for up to 24 months and thereafter may store it in anonimised/aggregate form. Please note that some or all of the data provided by the users of those applications may be required in order for the application to function properly.
In relation to individuals who subscribe to our newsletter service, we will retain their email address and records of the newsletters received by them until they unsubscribe from this service, or we consider them to be inactive users. In particular, we will remove from our newsletter list any users who have not opened any newsletter emails for about three (3) months (provided prior consent was given to that effect).
As to competition data, we will delete it once the competition is finalised and the winner declared.
11.5. If you would like to know more about the retention periods we apply to your personal data, please contact us at [email protected] .
11.6. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
11.7. Notwithstanding the other provisions of this Section, we may retain your personal data for longer where such retention is necessary due to any pending legal proceedings and/or investigations by public authorities/bodies and/or other disputes/differences in relation to such data and/or if you granted us your consent for further retention.
12. Your personal data rights
12.1. We respect the right that have under the GDPR in relation to your personal information we hold about you, namely the following:
Right to access
You have the right to obtain from us confirmation as to whether or not data concerning you are being processed and, if that is case, access to such data and further information in relation to them. Provided that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
Right to rectification
You have the right to request and obtain from us rectification of inaccurate personal information concerning you and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
Right to erasure (“right to forget”)
You have the right to request us to delete or remove your data, where certain conditions apply, including where (a) we process such data on the basis of your consent and you refuse or withdraw such consent (as in Sections 2 and 3 herein above), provided that no other legal ground for processing applies and/or (b) we process your personal information in order to pursue our legitimate interests (as in Sections 2 and 3 herein above) and you object to such processing, provided that no overriding legitimate grounds for the processing apply.
Right to restrict processing
You have the right to request and obtain from us restriction (or “blocking”) of processing of your personal information for a certain period of time, provided that particular conditions apply [e.g. where you contest the accuracy of such data, for a period that allows us to verify the accuracy of such data; or where you have objected to us processing of your personal information on the grounds of our legitimate interests (as in Sections 2 and 3 herein above), until we verify whether the grounds on which we process such data override your rights and freedoms].
Right to object to processing
You can request from us, at any time, to stop processing your personal information for direct marketing purposes. Moreover, you have the right to object, at any time, on grounds relating to your particular situation, to us processing your personal data on the basis of our legitimate interests (as in Sections 2 and 3 herein above). Should you exercise this right, we will no longer process such data unless we are able to demonstrate compelling legitimate grounds for the processing.
Right to data portability
You have the right to receive a copy of the personal data that you have provided to us and to reuse it elsewhere and/or to request that we transmit such data directly to a third party of your choice, provided that:
we process such personal information on the basis of (a) your consent, or (b) for the performance of our contractual obligations, or (c) at your request, for the purposes of you entering into a contractual relationship with us (as in Sections 2 and 3 herein above); and
the relevant processing activities are carried out by automated means.
Right to withdraw consent
Where we process your personal information on the basis of consent (as in Sections 2 and 3 herein above), you have the right to refuse to give such consent. Moreover, where you have already given us such consent, you can revoke it at any time. Any such revocation will not affect the lawfulness of data processed prior to such revocation.
Right to lodge a complaint
You have the right to contact us for any issues regarding the way we process your personal information. If you are not satisfied or still concerned about any personal data-related issues, you are entitled to file a complaint with a competent supervisory authority.
More information on how to contact and/or file a complaint with the Office of the Personal Data Commissioner of the Republic of Cyprus
is available at: http://www.dataprotection.gov.cy.
13. Data security
13.1. We are committed to safeguarding the confidentiality and security of your personal data. We have put in place and implement physical, electronic, and procedural safeguards to protect the personal information we process and maintain it against loss, misuse, unauthorized access, disclosure and alteration. Such measures include firewalls, online encryption, access restriction and authorization controls. While we are dedicated to protecting your personal information, security cannot be absolutely guaranteed against threats. In the event that we become aware of a data breach which may cause you a disadvantage, we will notify you accordingly, without undue delay.
13.2. Moreover you are responsible for protecting and maintaining protection of any identification, authentication and other security measures regarding our services and products.
14. Our details
14.1. Our online products and services are owned and operated by us, i.e. ANTENNA LIMITED.
14.2. We are registered in Cyprus under registration number HE38259, and our registered office is at 5, Megaron Street, 2032 Strovolos P.O. Box 20293, 1665 Nicosia. Our principal place of business is at Nicosia.
14.3. You can contact us via www.ant1.com.cy or at the following contact details:
Tel: +357 22200200,
5, Megaron Str., 2032 Strovolos
P.O. Box 20293, 1665 Nicosia
Cyprus
15. Data protection officer
15.1. For any matters arising out of and/or in connection with the present Online Privacy & Cookies Policy, including for exercising your rights and requesting more information about how we process your personal information, you may contact our Data Protection Officer at [email protected] .
16. Changes to this Online Privacy & Cookies Policy
We may modify this Online Privacy & Cookies Policy from time to time in order to reflect our current practices and/or in accordance with any changes in the applicable legal framework. In such an event, we will update the revision date at the top of the page and notify you accordingly, including by placing a notice to that effect on our website. You should check this page occasionally to ensure you are happy with any changes to this Online Privacy & Cookies Policy.
Privacy Policy for ant1.com.cy APPS for iOS & Android
This privacy policy governs your use of the software application ant1.com.cy (“Application”) for mobile devices that was created by ANTENNA LTD.
What information does the Application obtain and how is it used?
Automatically Collected Information
The Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, and information about the way you use the Application.
Do third parties see and/or have access to information obtained by the Application?
No. We will not share your information with third parties.
What are my opt-out rights?
You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
Data Retention Policy, Managing Your Information
We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.
Security
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
Changes
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here . You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.
Your Consent
By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information.
Contact us
If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at [email protected]