Introduction

This Privacy Notice will inform you as to how Telxi LTD (hereinafter referred to as the “Company”, “Telxi”, “we”, “us” and “our”) collects and processes information about you and in particular, your personal data. We hereby assure you that this Privacy and Personal Data Protection Policy (“Privacy Policy”) fully respects and complies with EU Regulation 2016/679 (the “GDPR”) and the relevant Law 125(I)/2018 of the Republic of Cyprus.

IMPORTANT: Telxi provides its Services exclusively for businesses purposes, sole traders and other legal entities (collectively “Customers”). For the avoidance of doubt a natural person who operates as a sole trader qualifies as a Customer solely in their capacity as a business operator and not in their capacity as a consumer. Telxi does not provide Services for residential or consumer usage. All Customers are responsible for ensuring that their own end users’ use of the Services complies with this AUP and all applicable laws and regulations.

Useful Definitions

“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, address, contact details, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

“Processing” means any operation or set of operations which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that person’s professional performance, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

“Third party” means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

The Controller

Regarding the personal data in cases where we determine the purposes and means of the processing, the Controller is: TELXI LTD, Offices 102-103, 17 Tepeleniou Str.,8010, Paphos, Cyprus. Tel: +357 26 913001. Email: legal@telxi.com.

Principles We Adhere To

At Telxi, we are committed to, and adhere to, the following principles of processing personal data in accordance with Article 5 of the GDPR. Personal data is:

• processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of “lawfulness, fairness and transparency”);
• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (principle of “purpose limitation”);
• adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (principle of “data minimisation”);
• accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay (principle of “accuracy”);
• kept in a form which permits identification of data subjects for no longer than is necessary or as required by relevant laws (principle of “storage limitation”);
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures (principle of “integrity and confidentiality”).

We are able to demonstrate compliance with the aforementioned principles (principle of “accountability”).

Collection of Personal Data

We, as the Controller, collect personal data from you in the following cases:

• When you contact us directly or indirectly (e.g., through our webpage and/or email, or through our collaborators, or through our social media accounts) in order to be informed regarding our services or to request relevant information;
• If you receive our services, cooperate with us, or are involved in events related to the offer and delivery of our services;
• If you fill in any of our documents or submit a message through our webpage, our email, or when you are connected to our social media accounts;
• When your personal data is disclosed to us by third parties under contracts or agreements;
• When you visit our webpage or our premises;
• When you are an employment candidate;
• When you are one of our employees.

We also process personal data which third parties — usually legal entities — disclose to us when we act as Processors on their behalf. In such cases, those third parties hold the responsibility to properly inform you.

Minors’ Personal Data

We do not collect and/or process minors’ personal data without verifiable parental consent, in cases where we are able to control it. As Telxi provides its Services exclusively to businesses and legal entities, we do not knowingly collect personal data directly from minors. If we become aware that personal data of a minor has been submitted to us without appropriate consent, we will take steps to delete it promptly.

Categories of Data Subjects

The categories of data subjects include:

• Representatives, executives, employees, and contact persons of our business Customers and partners who contact us or whose data is shared with us in the context of a business relationship;
• Natural persons receiving our services or related to the delivery of our services, or natural persons and employees of our suppliers and other legal entities cooperating with us;
• Candidates for employment;
• Visitors of our premises or our webpage and our social media accounts;
• Our employees.

Regarding the categories of data subjects and the personal data we process when we have the role of Processor, the Controller holds the responsibility to appropriately inform you.

Personal Data Types That We May Collect as Controller

Data from the following categories of personal information may be collected and processed per case and not as a whole, when we are the Controller, in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Policy:

• Contact details for you or a natural person you may indicate instead of you (name, surname, address, telephone, email);
• Occupational information (occupation, position, company);
• Information related to terms of agreements (yours or persons involved) such as identification card or passport or ARC number, date and place of birth, nationality, date of issue of the passport and its expiry date, terms of the service, dates, signatures and amounts;
• Payment and transaction details (IBAN, account number, tax number, desired payment method, terms of payment, depositor’s details);
• Incident investigation data, such as incident details, data of persons involved or related information;
• Customer or provider history (satisfaction, transaction details, claims, problems, terms) and information related to assessing persons and situations;
• Apps / websites / social media related data (cookies, full name or nickname, information you publicly disclose and comments on social media, or email attachments);
• Your image captured through our legally operating CCTV system when you are visiting our premises;
• Data included within your Curriculum Vitae such as data related to studies, competencies or previous working experience, and other information included therein, if you disclose this information to us as a candidate for employment.

We collect some additional types of personal data about our employees; they are informed through documents, manuals, policies and procedures and information provided internally.

Purposes of Processing and Legal Basis

The processing of personal data by us as the Controller is based on one of the legal bases referred to in Article 6 of the GDPR (or Article 9 in case of special categories of personal data).

The legal bases on which the collection and processing of personal data is based are:

• your consent (Article 6(1)(a)) or explicit consent (Article 9(2)(a)) in the case of special categories of personal data. We do not collect and process special categories of personal data without your explicit consent;
• processing that is necessary for the performance of a contract to which you as the data subject are a party, or in order to take steps at your request prior to entering into a contract (Article 6(1)(b));
• compliance with our legal and statutory obligations (Article 6(1)(c));
• safeguarding our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of yours as the data subject (Article 6(1)(f)).

The legal basis for each processing purpose is as follows:

Consent: when you communicate with us in any way directly or indirectly as interested in our services, when you are interested in working with us, when you fill in our documents, when you make a complaint, when you visit our social media accounts, when you give us your business card or when you agree to receive information from us.

Performance of a contract: when you have agreed to receive our services, when you are our employee or collaborator, during the payment of our liabilities or when we are contacting you in the framework of a contract.

Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or during payment of our liabilities.

Safeguarding our legitimate interests: to improve our services, when investigating and managing any potential incident, to receive our payment, or for the assessment of persons and situations. This specific legal basis also applies to the CCTV operation on our premises that we operate for the protection of people and property.

Our employees are informed internally about the processing purposes and the legal basis under specific documents.

Retention of Data

We store personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose.

• Data collected on the basis of contractual and legal obligations shall be retained after the expiry of those obligations as provided by the relevant institutional framework (7 years for accounting/tax records (Cyprus Income Tax Law), 5 years for AML records (if applicable), and 3 years for general contract records under the Limitation of Actions Law.)
• Personal data included in offers that do not lead to a cooperation agreement is kept for 2 years.
• Cookies are stored depending on their nature as described in our Cookies Policy.
• Personal data you disclose to us as a candidate is stored for 6 months or until you revoke your consent.
• CCTV recordings are maintained for 15 days and then anonymised by overwrite.
• Data that may be needed for our legitimate interests as Controller shall be kept until the reason for storing such data ceases.
• Data processed on the basis of your consent is kept from the time consent is obtained until it is revoked or there is no longer a need to store it.

Information that is no longer necessary is securely destroyed or anonymised. We limit access to your personal data to those employees who need to use it for a specific purpose.

How We Ensure the Security of Personal Data

We have implemented reasonable organisational and technical measures to protect the personal data we collect, and in particular any special categories of personal data. We follow international standards including the ISO 27001:2022 Standard to ensure the security of our operations. We ensure that your personal data is processed securely and lawfully by adhering to policies and implementing procedures in accordance with the purposes and legal basis of processing. Security measures include:

• Access to personal data is restricted to a limited number of authorised employees on a need-to-know basis, and the necessary data transfer is done by secure procedures.
• Our employees adhere to strict confidentiality rules and agreements, with access to classified data restricted solely to what is essential for their roles.
• We select trusted collaborators who are committed in writing, in accordance with Article 28 of the GDPR, to the same obligations regarding the protection of personal data. We reserve the right to audit them in accordance with Article 28(3)(h).
• In our ICT systems used for the processing of personal data, all technical measures are taken to prevent loss, unauthorised access or other unlawful processing. Access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage.

Some of the security measures we take are not disclosed for obvious reasons. Although the transfer of data through the Internet or a website cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.

Recipients

We take measures to ensure that the recipients of personal data we process as the Controller are kept to a minimum. The personal data we collect is disclosed to third parties only where the legality of such disclosure is fully justified. Such processing by third parties is usually view-only, and only under specific circumstances may include the retention of such data by the third-party recipient — especially in relation to authorities, legal cases, payments, or incident investigations. Specific personal data from those we lawfully collect as a Controller may be accessed or disclosed on a case-by-case basis by:

• Any relating supervisory authority within its role;
• Any public or judicial authority where required by law or judicial decision;
• The auditor of the company, for data required to fulfil the audit (financial, employment, contracts and other controls), under confidentiality;
• The legal advocate, for whatever data is required in legal cases, under confidentiality;
• The insurance cooperating company and only for the relevant part of the information;
• Partner banks (of the company, the staff or affiliates and suppliers), only for payment-related data;
• Training or systems consultants, for training or systems control issues and only for the necessary pieces of information under confidentiality agreements;
• The Certification Body during their audits.
• IT systems and infrastructure providers

Territorial Scope

The personal data we collect is processed within the European Economic Area (EEA) or outside the UK where the UK GDPR applies, subject to appropriate safeguards under UK GDPR  and/or an adequacy decision area pursuant to Article 45 GDPR. Where any transfer of personal data outside the EEA is necessary, such transfer shall be subject to appropriate safeguards in accordance with Chapter V GDPR, such as Standard Contractual Clauses adopted by the European Commission.

Your Rights as a Data Subject

You have the following rights under Applicable Data Protection Law: the right to be informed, the right of consent where this is the legal basis of data collection and processing, the right of access to your personal data, the rights of rectification and erasure (in cases where it is permitted), the right to restriction of processing, the right to data portability, the right to object, and the right not to be subject to solely automated decision-making including profiling where this produces significant legal or similar effects. If processing is based on your consent, you may withdraw it at any time.

Right to be Informed

The right to be informed is exercised through this Privacy Policy. In some cases, it is also mentioned in documents and forms we use.

Right of Access

You have the right to obtain from us confirmation as to whether or not your personal data is being processed, as well as other relevant information, and — where that is the case — access to your personal data.

Right of Rectification

You have the right to rectification of your inaccurate personal data, as well as to have incomplete personal data completed by providing a supplementary statement. Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by notifying us of any changes.

Right to Erasure (‘Right to be Forgotten’)

We must respond to such a right when:

• your personal data is no longer necessary in relation to the purposes for which we collected it;
• you withdraw your consent on which the processing is based and there is no other legal basis for the processing;
• your personal data has been unlawfully processed;
• your personal data has to be erased for compliance with a legal obligation we are subject to;
• your personal data has been collected in relation to the offer of information society services.

We reserve the right to refuse this right if the processing is necessary for compliance with a legal obligation we are subject to, for reasons of public interest, or for the foundation, exercise or defence of legal claims (Article 17(3) GDPR).

Right to Restriction of Processing

You have the right to restriction of processing when:

• you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need your personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims;
• you have objected to processing pending the verification whether our legitimate grounds override yours.

Right to Data Portability

You have the right to receive your data in a structured, commonly used and machine-readable format and, under an explicit request, to have such data transferred to both you and another natural or legal person who will process it, when:

• the processing is based on consent or the data were processed for the performance of a contract to which you were a party; and
• the processing is carried out by automated means.

Right to Object

You have the right to object to the processing of your data at any time when:

• the processing is based on legitimate interests or the performance of a task in the public interest, including profiling on those bases — we shall cease processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims; or
• the processing relates to direct marketing, including profiling to the extent it is related to such direct marketing — in this case we shall cease processing your personal data for those purposes immediately and without exception.

Profiling and Automated Decision-Making

We are committed to transparency regarding any use of profiling or automated decision-making in connection with your personal data.

Automated Decision-Making

We do not make decisions about you that are based solely on automated processing — including profiling — which produce legal effects concerning you or similarly significantly affect you, within the meaning of Article 22 GDPR. All significant decisions affecting you are made with human involvement.

Profiling Activities

We may carry out limited profiling activities in connection with the following purposes, where a human reviewer is involved in any outcome that affects you:

• Fraud prevention and network security: we may analyse usage patterns and behavioural data associated with Customer accounts to detect unusual or potentially fraudulent activity. This profiling is based on our legitimate interests in protecting the integrity of our network and services (Article 6(1)(f) GDPR).
• Service improvement and account management: we may use aggregated or pseudonymised data to analyse how our services are used by business Customers, in order to improve service quality and tailor our communications. This is based on our legitimate interests (Article 6(1)(f) GDPR) or, where applicable, your consent.
• Marketing communications: where you have consented or where we have a legitimate interest, we may use contact and occupational information to segment our communications and send relevant information about our services. You may object to this at any time (see Right to Object above).

We do not carry out profiling of individual consumers or end users of our business Customers, as Telxi does not have a direct relationship with such individuals.

Your Rights in Relation to Profiling

Where profiling is carried out on the basis of legitimate interests, you have the right to object at any time by contacting us using the details set out in the Contact section below. Where profiling is based on your consent, you may withdraw consent at any time. We will respond to any such request within one month.

Personal Data Breach

In the event of a breach of the security and integrity of the personal data we process, we will take the following measures in accordance with Articles 33 and 34 GDPR where we are the Controller:

• Assess it in order to implement the appropriate procedures needed to limit the breach;
• Examine the extent of the breach and the sensitivity of the data included;
• Evaluate the risk and its impact on your rights and freedoms;
• Endeavour to reduce as much as possible the damage that is or may be caused;
• Notify the Cyprus Personal Data Protection Authority within 72 hours of becoming aware of the breach, where required;
• Where the breach is likely to result in a high risk to your rights and freedoms, notify you without undue delay;
• Assess the impact on your privacy and take appropriate measures to prevent recurrence.

Where we are the Processor, we will inform the Controller as soon as possible and in any event within 72 hours of becoming aware of the breach.

Links to Other Websites

Our website may contain links to other websites that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third-party site. We recommend that you review the Privacy Policy for each site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Contact Details of the National Data Protection Authority

Cyprus Personal Data Protection Authority, Email: commissioner@dataprotection.gov.cy.

Additional information and terminology for the GDPR can be found at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679

Contact Us

If at any time you wish to contact us or make a request regarding your rights or any other matter relating to the protection of personal data, you may contact us at:

Telxi LTD, Offices 102-103, 17 Tepeleniou Str., 8010, Paphos, Cyprus. Tel: +357 26 913001. Email: legal@telxi.com.

Communication languages are English and Greek only.

Policy Update

This policy was updated in June 2026 and may be reviewed when there is a significant change. Any review will be available on our website with a note of the effective date.