Privacy Policy

Privacy Policy

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how The Emeri Foundation (“The Emeri Foundation”, “we”, “us”, “our”) collects and uses your personal data through your use of this website, including any data you may provide when you interact with us.

This website is not intended for children, and we do not knowingly collect data relating to children.

Controller

The Emeri Foundation is the controller and responsible for your personal data. The Emeri Foundation is committed to protect all personal data it collects in accordance with the provisions of the EU General Data Protection Regulation 2016/679 (“GDPR”), and the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data Law 125(I)/2018, as amended (the “Cyprus Personal Data Law”).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use and store different kinds of personal data you have sent to us via the website.

3. How is your personal data collected?

We only collect data as follows:

  • Your interactions with us. You may give us your personal data by filling in the application of The Emeri Foundation for granting donations or by corresponding with us by post, phone, email or otherwise.

4. How we use your personal data

4.1. Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: We may process your personal data where it is necessary for the performance of a contract to which you are a party, for example when we engage with you as a service provider, donor, partner or beneficiary and need to process your information to fulfil our obligations under that agreement.
  • Legitimate interests: We may process your personal data where it is necessary for the legitimate interests of the foundation in carrying out our activities, provided that such interests are not overridden by your fundamental rights and freedoms. We ensure that any data processing is proportionate, relevant and limited to what is necessary in the context of our operations.
  • Legal obligation: We may process your personal data where it is necessary for compliance with a legal obligation that the foundation is subject to. For example, obligations related to tax reporting or compliance with regulatory or statutory reporting requirements.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

4.2. Purposes for which we will use your personal data

We use your personal data to:

  • Process donations and issue receipts.
  • Communicate with you about our programs and events.
  • Ensure legal and regulatory compliance.

Respond to inquiries and requests.

5. Data Sharing and Transfers

We may share your information with:

  • Public authorities or regulators, if required by law
  • Third parties

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where personal data is transferred outside the European Union to countries which have laws that do not provide the same level of data protection, we always ensure appropriate safeguards are in place in compliance with the GDPR.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to your personal data is limited to individuals who have a legitimate need to know and are authorised to process it subject to the duty of confidentiality.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

8. Your legal rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes, such as distribution of newsletters, promoting events etc.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • If you want us to establish the data’s accuracy;
    • Where our use of the data is unlawful, but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
    • If you wish to exercise any of the rights set out above, please contact us as per Section 9 below.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Contact details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

  • Email address: [email protected].
  • Postal address: 12 Demostheni Severis Avenue, 6thfloor, Office 601, 1080 Nicosia, Cyprus.
  • Telephone number: 22465500

10. Complaints

You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, the Cyprus regulator for data protection issues (www.dataprotection.gov.cy). We would, however, appreciate the chance to deal with your concerns before you approach the Office of the Commissioner for Personal Data Protection so, please contact us in the first instance.

11. Changes to the privacy policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. This version was last updated in May 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.