This Privacy Policy explains how personal data is collected, used and protected when you visit this website, contact us or subscribe to our communications.
We process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation – GDPR) and other applicable data protection laws.
The controller responsible for the processing of personal data through this website is:
Clear Mind Financial Services Ltd
Dikmou 31, Lakatamia,
2323 Nicosia,
Cyprus
Email: [email protected]
Hereinafter referred to as “ClearMind”, “we”, “us” or “our”.
Depending on how you use the website, we may process the following categories of personal data.
When you visit the website, certain technical information may be processed automatically, including:
This information may be processed for the operation, security, performance and protection of the website.
If you contact us through a form, email or another communication channel, we may process information such as:
We use this information to respond to your enquiry, provide requested information and, where relevant, take steps prior to entering into a business relationship.
If you subscribe to our newsletter or other email communications, we may process:
You can unsubscribe from marketing communications at any time by using the unsubscribe link contained in our emails or by contacting us.
We process personal data for the following purposes.
Technical data may be processed to:
The legal basis is our legitimate interest in operating and securing our website, pursuant to Article 6(1)(f) GDPR.
Information submitted through our contact channels is processed in order to respond to requests and communicate with prospective or existing clients.
Depending on the nature of the enquiry, the legal basis is:
Where you provide consent, we may use analytics technologies to understand how visitors interact with our website, measure traffic and improve its content and performance.
The legal basis for this processing is your consent, pursuant to Article 6(1)(a) GDPR.
Analytics technologies requiring consent are not intended to be activated before the relevant consent has been obtained.
You may withdraw your consent at any time through the cookie settings available on the website.
We send newsletters and other marketing communications where you have requested them or otherwise provided the necessary consent.
The legal basis is your consent, pursuant to Article 6(1)(a) GDPR.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
We may retain limited information concerning an unsubscribe request where necessary to ensure that no further marketing messages are sent to that address and to demonstrate compliance with applicable law.
Where necessary, personal data may also be processed in order to:
The legal basis may be Article 6(1)(c) GDPR, where processing is required by law, or Article 6(1)(f) GDPR where necessary to protect our legitimate interests and legal rights.
We use services provided by Cloudflare to improve the security, reliability and performance of the website.
When you access the website, Cloudflare may process technical information such as your IP address, request information, browser and device information, timestamps and security-related data.
Cloudflare may process such information for purposes including:
Certain Cloudflare technologies may be strictly necessary for security and the technical operation of the website and may therefore operate without consent where permitted by applicable law.
Cloudflare operates a global infrastructure and personal data may in certain circumstances be processed outside the European Economic Area. Appropriate safeguards are used for international transfers in accordance with applicable data protection law.
Subject to your consent, this website uses Google Analytics 4, a web analytics service provided by Google.
Google Analytics may process information including:
Google Analytics may use cookies such as _ga to distinguish users and sessions when analytics storage has been authorised.
For users accessing the website from the European Economic Area, Google states that IP addresses are used for geographical lookup and are not logged or stored as individual IP addresses in Google Analytics.
Google Analytics is only intended to operate after the user has provided the required consent.
You can withdraw or change your consent at any time through the website’s cookie settings.
Google Analytics data is retained according to the retention settings configured for our Analytics property.
[TO CONFIRM BEFORE PUBLICATION: GA4 user/event data retention setting – normally choose either 2 months or 14 months.]
Where information is transferred outside the European Economic Area, such transfers are carried out using the safeguards applicable under data protection law.
We use Mailrelay, operated by CPC Servicios Informáticos Aplicados a Nuevas Tecnologías, S.L., to manage newsletter subscriptions and send email communications.
Mailrelay processes personal data on our behalf as a data processor for the purposes of:
The principal information transmitted to Mailrelay may include your email address, name where provided, subscription information and information relating to delivery or interaction with our communications.
Mailrelay processes personal data on our instructions and under a data processing agreement in accordance with Article 28 GDPR.
You can unsubscribe from our newsletter at any time using the unsubscribe link contained in each marketing email.
Our website may use cookies and similar technologies.
Some technologies are necessary for the website to function correctly, maintain security, remember privacy preferences or protect the website against malicious activity.
Where these technologies are strictly necessary, they may be used without consent.
Analytics cookies and similar technologies are used only after you have provided the required consent.
You can accept, reject or modify your choices through the cookie consent interface available on the website.
Further details about individual cookies, their providers, purposes and duration will be provided in our Cookie Policy or cookie preference interface.
Some pages may contain content or services provided by third parties, such as videos, maps, external media or links to other websites.
When such external content is loaded, the relevant third-party provider may receive technical information about your device and connection and may use cookies or other technologies.
Where third-party content involves non-essential tracking technologies, it will be loaded only after the required consent has been obtained, where applicable.
Third-party websites and services operate under their own privacy policies, and we are not responsible for their independent processing activities.
We may disclose personal data to service providers where necessary for the operation of the website and our business.
These may include:
Where a service provider processes personal data on our behalf, we require it to process such data in accordance with applicable data protection requirements.
We do not sell personal data.
Some of our service providers operate internationally.
As a result, personal data may in certain circumstances be processed in countries outside the European Economic Area.
Where such transfers are not covered by an adequacy decision of the European Commission, we rely on appropriate safeguards provided by Chapter V GDPR, such as Standard Contractual Clauses or other recognised transfer mechanisms, where applicable.
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and to comply with applicable legal requirements.
In particular:
Personal data may be retained for a longer period where required by law or where necessary for the establishment, exercise or defence of legal claims.
Under the GDPR, subject to the conditions provided by law, you may have the right to:
Where processing is based on consent, withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
Requests concerning your personal data may be sent to:
[privacy/contact email]
We may need to request reasonable information to verify your identity before responding to a request.
If you believe that the processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with a competent supervisory authority.
Where ClearMind is established in Cyprus, the relevant supervisory authority is:
Office of the Commissioner for Personal Data Protection
Republic of Cyprus
You may also have the right to lodge a complaint with the supervisory authority in the EU or EEA country in which you live, work or where you believe an infringement has occurred.
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
However, no method of transmission or electronic storage can guarantee absolute security.
We may update this Privacy Policy when our website, services, data processing activities or applicable legal requirements change.
The latest version will always be published on this page, together with the date on which it was last updated.
For questions about this Privacy Policy or the processing of your personal data, please contact:
Clear Mind Financial Services Ltd
Dikmou 31, Lakatamia,
2323 Nicosia,
Cyprus
Email: [email protected]