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Privacy Policy

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This privacy policy aims to explain how OINOESSA LTD (hereinafter referred to as “Oinoessa”) processes the personal data collected from you.

1. What type of personal data do we collect

  • Full Name & Date of birth
  • Passport/ID
  • Residential & Business Address
  • Contact Information
  • Personal & Marital status and information
  • Occupation, Name & address of Employer
  • Data required to fulfil legal obligations of our firm
  • Credit Card Information

2. How and when do we collect your data

You directly provide our firm with most of the data we collect. We collect data and process data when:

  • You request our services;
  • During the time of provision of services;
  • Cookies on use or view of website;
  • Voluntarily for quotation purposes;
  • Pursuant to a written agreement and/or booking with Oinoessa.

Oinoessa may also receive your data indirectly from online sources, databases or authorised third parties in order to be able to facilitate and to accommodate your needs or for scientific and statistical purposes.

3. Purposes of data processing

Oinoessa collects your data for purposes, including but not limited to:

  • As part of our Know your client policy;
  • Pursuant to Anti-Money Laundering & Anti-Terrorism laws;
  • Reporting to our regulatory authorities;
  • Reporting to you on provided services;
  • Accommodating your needs in order to improve the quality of our services.

4. Sharing, disclosure and transferring of your Personal Data

Oinoessa may share and/or disclose your personal data with:

  • Partners/associates for the purposes of providing you with a better service.
  • Third parties that perform services on our behalf:
    1. to improve the quality of our services;
    2. required for complying with our legal and/or contractual obligations;
    3. instructed or authorised by you to do so.

5. Storing your Personal Data

Oinoessa securely stores your data at:

  • in a physical server which is secured adequately from potential cyber or physical threats, and
  • electronically in external servers

The combination of both online/electronic and physical storage of data ensures that in the event of an unforeseen event which might cause destruction and/or loss of data, we will be able to assess the level of destruction and/or loss, to identify the lost data and to mitigate the potential risks involved.

After a period of 7 (seven) years from the day of termination of our business relations, we delete and remove from all our systems all information and data you provided us with or, where practically and legally possible, upon your request.

6. Your Rights – Lodging a complaint or Filing a Request

  • The right to be informed: about the type of your personal data which are under our processing activities, details about us as a controller/processor and the purpose and type of processing.
  • The right to access: the personal data collected at any given time.
  • The right to rectification: to request for incomplete or inaccurate information to completed or updated.
  • The right to erasure: you may withdraw your consent for the processing of your personal data by us at any given time and to request that your personal data be deleted.
  • The right to objection: you have the right to object to a part or the whole of the processing activities performed by our firm.
  • The right to data portability: you have the right to request that our firm transfers the personal data that we have collected to another organization, or directly to you.

Oinoessa would like to make sure you are fully aware of all of your data protection rights. You have the right, at any time, to file such a request to us if you would like to exercise any of your abovementioned rights.  In addition, you may also file a complaint if you believe that we do not process your personal data in accordance with the GDPR and the Data Protection Law (Law 125(I)/2018). You may contact us at:

Tel: +357 99-373371
Email Address: [email protected]
Office Address: Georgiou Karaiskaki 38, Kanika Alexander Center, 2nd Floor, Office 213B, 3032 Limassol Municipality, Limassol, Cyprus.

Contact Person/DPO: Georgios Diogenous

Where you believe that your complaint and/or request is not treated fairly by us you may recourse to the Competent Authority in Cyprus for the protection of Personal Data at:

Office of the Commissioner for Personal Data Protection:

Office address:
Iasonos 1, 1082 Nicosia, Cyprus
Tel: +357 22818456
Fax: +357 22304565
Email: commissionerdataprotection.gov.cy

Postal address:
P.O.Box 23378, 1682 Nicosia, Cyprus

7. Cookies

Our firm’s website uses cookies to improve user experience.

Cookies allow websites to remember your settings and other browser preferences. Our firm will not use cookies for any purposes not stated in our Privacy Policy.

Visitors who do not wish to have the Cookie Policy applied on their computer should make the necessary changes using their browser instruction.

8. Changes to our privacy policy

Our firm keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 11 September 2026.

9. How to Contact us

If you have any questions about our firm’s Privacy Policy, please refer to our extended Privacy Police Notice.

Should you require further clarifications as to your personal data we process, should you wish to exercise your data protection rights, please do not hesitate to contact us.

Tel: +357 99-373371                                                

Email Address: [email protected]

Office Address: Georgiou Karaiskaki 38, Kanika Alexander Center, 2nd Floor, Office 213B, 3032 Limassol Municipality, Limassol, Cyprus.

Contact Person/DPO: Georgios Diogenous

Turnstile Privacy Addendum

Last updated: JUNE 18, 2025

  1. INTRODUCTION

Turnstile, developed by Cloudflare, Inc. (Cloudflare), is a pro-privacy website security tool that processes minimal Signals (as defined below) solely to protect web properties against malicious activity by distinguishing human users from bots and blocking bot traffic.

Cloudflare does not control whether a website chooses to use Turnstile; instead, we make Turnstile available to any website that is looking for a way to detect and block bot traffic.

  1. SCOPE OF THIS ADDENDUM

This Turnstile Addendum is supplemental to Cloudflare’s main Privacy Policy. It provides additional information specific to your use and interaction with Turnstile. This Addendum also applies to the personal data processed using Cloudflare’s Challenge Platform, and any reference to “Turnstile” in this addendum applies equally to the Challenge Platform.

The Cloudflare Privacy Policy continues to apply to your use and interaction with Turnstile, except where this Turnstile Addendum provides more specific information. In those cases, the more specific information will apply instead.

  1. INFORMATION WE COLLECT

Cloudflare Turnstile processes a variety of client-side signals (“Signals”) such as client IP address, TLS Fingerprint, User-Agent Header and Sitekey and associated origin. Cloudflare does not have the ability to directly identify any individuals from any of the Signals Turnstile collects, including IP addresses.

  1. HOW WE USE INFORMATION WE COLLECT

(i) Bot detection and blocking

Turnstile is a tool to protect web properties by distinguishing human users from bots and blocking any detected bot traffic that could otherwise harm the safety and security of that property.

It does so by evaluating the Signals listed above specific to both the website visitor and the website visited. The purpose of collecting these Signals is not to identify, profile or target any individuals but solely to detect and block bots. The Signals collected by Turnstile are strictly necessary for this purpose (i.e. detecting and blocking bots to enable visitors to enjoy a safe and secure experience when visiting websites that have implemented Turnstile).

Cloudflare is a data processor of Signals that we process to provide the Turnstile service to our customers, that is, securing our customers’ websites. This means that we process Signals for this purpose on behalf of, and pursuant to instructions issued by, our website operator customers (who are the data controllers of any data processed for this purpose). If you have questions, or wish to exercise any data protection rights, regarding Cloudflare’s processing of Turnstile data to provide our service, please contact the relevant website operator.

(ii) Improving Turnstile’s bot detection capabilities

Cloudflare also processes the Signals described in this Privacy Notice to improve Turnstile. This is necessary to refine and improve our bot detection algorithms in order to respond to evolving bot threats, and to maintain the security of the web properties that website visitors choose to visit.

Cloudflare is a data controller of Signals that we process to improve Turnstile’s bot detection capabilities. This Turnstile Privacy Notice (in conjunction with Cloudflare’s main Privacy Policy) governs our processing of Signals for this purpose.

  1. NOTICE TO EU AND UK RESIDENTS

To the extent that the data described in the Turnstile Privacy Notice qualifies as personal data, then:

  • When processing this personal data as a processor to protect our customers’ websites, our customers, as controllers, determine the lawful basis of this processing, and we process this data under their instruction and on their behalf; and
  • When processing this personal data as a controller, we rely on our legitimate interests in improving the effectiveness of Turnstile’s bot detection capabilities to process this Turnstile data.
  1. COOKIES

The Signals collected by Turnstile are strictly necessary for the purpose of detecting and blocking bots to enable visitors to enjoy a safe and secure experience when visiting websites that have implemented Turnstile.

For more information about the cookies used by Cloudflare, please check our Cookie Policy and our Turnstile Developer Docs.

CONTACT FOR PRIVACY CONCERNS

If you have questions or concerns about this Turnstile Privacy Notice or your personal data processed through Turnstile, please contact Cloudflare’s Data Protection Officer at [email protected].