1. Introduction
This Privacy Policy explains how demzine (the “Company,” “we,” “us,” or “our”), operating the website demzine.com (the “Website”), collects, uses, shares, and protects your personal data.
We are committed to protecting your privacy in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Cypriot Law 125(I)/2018 (The Law Providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of Such Data).
Data Controller Contact Details
The Data Controller responsible for the processing of your personal data is:
Company Name: Christodoulos Demosthenous
Website: demzine.com
Registered Address: 5 Pavlou Kalorides Street, 2051 Strovolos, Nicosia, Cyprus
Email for Privacy Matters: info@demzine.com
2. Personal Data We Collect
We collect personal data that you provide to us directly and data that is automatically collected when you use our Website.
Data Provided Directly by You (Voluntary Data)
Identity Data: Name, username, if you create an account.
Contact Data: Email address, telephone number, mailing address (if applicable, e.g., for zine subscriptions).
Correspondence Data: Information you provide when contacting us via contact forms, email, or customer support.
Content/Contribution Data: If you submit articles, comments, or other content to the Website.
Data Collected Automatically (Technical Data)
Device Data: Internet Protocol (IP) address, browser type and version, operating system, and unique device identifiers.
Usage Data: Information about how you use our Website, including the pages you view, the time spent on those pages, and referring website addresses.
Location Data: General geographical location inferred from your IP address.
Cookies: Data collected via cookies and similar technologies (see Section 5).
3. Legal Bases and Purposes for Processing
We will only process your personal data when we have a valid legal basis to do so, as set out in Article 6 of the GDPR.
|
Purpose of Processing |
Categories of Data Processed |
Legal Basis (GDPR Article 6) |
|---|---|---|
| To provide and maintain the Website | Identity, Contact, Technical, Usage | Contract (Necessary for the performance of a contract or to take steps at your request before entering a contract.) |
| To manage your account (if applicable) | Identity, Contact | Contract (To manage the contractual relationship with you as a user.) |
| To send newsletters/marketing (only if subscribed) | Contact (Email) | Consent (You have explicitly agreed to receive marketing communications.) |
| To analyze and improve the Website performance | Technical, Usage | Legitimate Interest (To study how users use our Website, to develop and improve our services, and ensure security.) |
| To comply with legal obligations | All categories | Legal Obligation (Necessary for compliance with a legal obligation to which we are subject, such as tax or regulatory requirements under Cypriot or EU law.) |
4. Children’s Personal Data (Cyprus Law Derogation)
The Cypriot Data Protection Law (Law 125(I)/2018) sets the age of consent for children at 14 years old.
We do not knowingly collect personal data from children under the age of 14. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at [INSERT PRIVACY EMAIL] so we can take appropriate steps to delete it. For users aged 14 and over, we process data based on the legal bases listed in Section
5. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to track activity on our Website and hold certain information.
What are cookies? Cookies are small data files stored on your device.
What do we use them for? We use them for essential Website functionality (strictly necessary cookies), analytics (to see how our site is used), and potentially for personalization or marketing.
Your Control: In compliance with the e-Privacy Directive and GDPR, we will seek your prior explicit consent for any non-essential cookies (e.g., advertising or performance/analytics cookies). You have the right to refuse or withdraw consent for these cookies at any time via our cookie banner/settings interface.
6. Disclosure of Personal Data to Third Parties
We may share your personal data with the following types of recipients:
Service Providers (Processors): Third parties who provide services to us, such as website hosting, analytics providers (e.g., Google Analytics – note their GDPR compliance), and email service providers. They process data only on our documented instructions.
Affiliates: Other entities within our company group (if applicable) for internal administrative purposes.
Law Enforcement/Authorities: When required by law, such as in response to a court order, legal obligation, or a request from the Cypriot Commissioner for Personal Data Protection.
Business Transfers: In connection with a merger, sale of company assets, or acquisition.
7. International Transfers of Data
Your data may be processed in, or transferred to, countries outside the European Economic Area (EEA) (also known as third countries).
If we transfer your personal data outside the EEA, we ensure that an adequate level of protection is afforded to it by implementing at least one of the following safeguards:
Adequacy Decision: Transferring data to countries deemed by the European Commission to provide an adequate level of protection.
Standard Contractual Clauses (SCCs): Utilizing the contractual clauses approved by the European Commission, combined with appropriate supplementary measures.
Derogations: Relying on a derogation for specific situations, such as your explicit consent.
8. Data Security and Retention
8.1 Data Security
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we process. These measures include [INSERT EXAMPLE MEASURES, e.g., encryption, access control, regular security audits].
8.2 Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data, and applicable legal requirements.
9. Your Data Protection Rights (GDPR)
Under the GDPR and Cypriot Law, you have the following rights:
Right to be Informed (Art. 12-14): The right to clear, transparent, and easily understandable information about how we use your personal data.
Right of Access (Art. 15): The right to obtain a copy of your personal data we hold.
Right to Rectification (Art. 16): The right to have your personal data corrected if it is inaccurate or incomplete.
Right to Erasure (‘Right to be Forgotten’) (Art. 17): The right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing.
Right to Restrict Processing (Art. 18): The right to block or suppress further use of your personal data.
Right to Data Portability (Art. 20): The right to receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller.
Right to Object (Art. 21): The right to object to certain types of processing, including direct marketing.
Rights in relation to automated decision making and profiling (Art. 22).
Exercising Your Rights
To exercise any of these rights, please contact us using the contact details provided in Section 1.1. We will respond to your request within one (1) calendar month.
10. Right to Lodge a Complaint
If you have any concerns about our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority.
In Cyprus, the supervisory authority is the Commissioner for Personal Data Protection.
Address: 1 Iasonos Street, P.C. 1082, Nicosia, Cyprus
Website: https://www.dataprotection.gov.cy
Email: commissioner@dataprotection.gov.cy