INTRODUCTION
Homemake By Irakleous (hereinafter “we”, “us” or “our”) is the controller of the information collected or provided directly.  And the individual visiting the webpage is interchangeably referred to as ‘‘user’’, “them” or ‘‘they’’.

We respect the user’s privacy and are committed to protecting it through our compliance with applicable privacy and data protection laws and regulations. Please read this privacy policy carefully to understand our policies and practices regarding user’s information and how we will treat it.

If a user has any questions regarding the contents of our privacy practices, please refer to the end of this privacy policy for information on how to contact us. 

This privacy policy applies to information we collect directly from users or through third parties in the standard course of the business we do in order to provide them with the service user requested.

COLLECTION OF PERSONAL INFORMATION
We collect and use several types of information the individuals we co-operate with, including information by which user may be personally identified and that is defined as personal data or personally identifiable information under applicable law (“Personal Information”), such as user’s first and last name, e-mail address, billing information, demographics, telephone number, or other (online) contact information, personal details, health related information.

Categories of Personal Information we collect and use on or through our website include:

• Information that user provides by filling in forms, at the time of initial contact with us. 
• Personal Information entered during a contest or promotion sponsored by us, additionally when a problem is reported on the website by the user.
• Records and copies of correspondence (including e-mail addresses), if direct contact with Homemake By Irakleous is made.
  
  

PURPOSES FOR WHICH PERSONAL INFORMATION IS USED
In general, we use information collected about the user or that is provided by the user, including Personal Information and Sensitive Personal Information, for the following purposes:

• Provision of services

With the intent of providing the user with information, products or services that is requested from us; 

• Customer management

Managing user’s account, provision of customer support and with notices about user account, including notices, notices about changes to any products or services we offer or provide through it;

• Advertising:

Following explicit consent for communication about products or services that may be of interest to user either from us, our affiliates or other third parties;

• Functionality and security: 

We further use it with the intention of detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;

• Compliance:to enforce our terms and conditions and to comply with our legal obligations as these derive from the applicable laws or our regulators;
• In any other way we may disclose when the user provides the information; or for any other purpose with consent provided separately from this privacy policy.

DISCLOSURE OF PERSONAL INFORMATION
We want the user to understand when and to whom we disclose Personal Information and other information we have collected regarding activities on the Website. We do not share said Personal Information with third parties except as indicated below:

• Affiliates.We share the above categories of Personal Information with our subsidiaries and affiliates to the extent this is necessary for the purposes of provision of services, customer management, customization of content, advertising (if user has consented) and security, and compliance, or to the extent user has provided separately from this privacy policy;
• Service providers.To our authorized service providers that perform certain services on our behalf, including for purposes of provision of the services requested from us, customer management and security. These services may include fulfilling orders, processing credit card payments, risk and fraud detection and mitigation, providing customer service and marketing assistance. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. We have taken all reasonable steps to ensure that they comply with the current data protection regulations;
• Legal successors. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer user’s personal information uses it in a manner that is consistent with this privacy policy;
• Other. To the extent this is necessary to fulfill any other purpose not mentioned above for which the user provided Personal Information and, if applicable, user’s consent separately from this privacy policy.

We also disclose user Personal Information to other third parties, including official authorities, courts, or other public bodies:

• In response to a subpoena or similar investigative demand, a court order or other judicial or administrative order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; to comply with applicable law or cooperate with law enforcement, government or regulatory agencies; or to enforce our Website terms and conditions or other agreements or policies; or as otherwise required by law (including responding to any government or regulatory request). In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
• To the extent a disclosure is necessary in connection with efforts to investigate, prevent, report or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to maintain and protect the security and integrity of our website or infrastructure.

Third parties to whom we may disclose Personal Information may have their own privacy policies which describe how they use and protect Personal Information.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may transfer non-Personal Information and process it outside user’s country of residence, wherever the Website, its affiliates and service providers operate. We may combine non-Personal Information we collect with additional non-Personal Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis.

HOW WE STORE USER’S PERSONAL INFORMATION
The information that we collect about the user, including Personal Information, will be stored and processed in Cyprus and/or in remote cases in the Countries in which we and the third parties mentioned above maintain facilities. If user is located in the European Union or other regions with laws governing data collection and use that may differ from European data protection laws, please note that in the course of providing the user with the service requested we may transfer Personal Information to some of these countries and jurisdictions that have data protection laws that do not provide the exact same level of protection as in their jurisdiction, however we make every effort possible to verify and audit that the processor and sub processors provide the best level of protection of personal data.

RETENTION OF PERSONAL INFORMATION
To the extent we have collected user’s Personal Data for purposes of provision of services, customer management, and customization of content (for descriptions of these purposes see above), we keep their Personal Information for as long as they have an account with the Website, as needed to provide user with our respective services and in compliance with relevant laws of Cyprus. For further information regarding specific retention period please contact us at info@homemake.com.cy.

Personal Information used for advertising purposes will be stored for a period of 12 months.

The period for which we keep user’s Personal Information that is necessary for compliance and legal enforcement purposes varies and depends on the nature of our legal obligations and claims in the individual case. 

LEGAL BASES FOR COLLECTION, USE AND DISCLOSURE OF USER’S PERSONAL INFORMATION
There are different legal bases that we rely on to collect, use and disclose user’s Personal Information, namely:

• Consent: We will rely on user’s consent to use (i) user’s Personal Information for marketing and advertising purposes; (ii) user’s Personal Information for other purposes when we ask for their consent separately from this privacy policy and for which the purpose of the process does not relate to the services we offer to them;

The use of their Personal Information for purposes of providing the services, customer management and functionality and security as described above is necessary to perform the services provided to user under our term and conditions and any other contract that user has with us;

• Compliance with legal obligations:We are permitted to use their Personal Information to the extent this is required to comply with a legal obligation to which we are subject.

How We Protect the Security of User’s Personal Information

We take appropriate security measures (including physical, electronic and procedural measures) to safeguard user’s Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition we have trained our employees on how to handle, manage and process personal data, applied upgraded technical measures and transformed our policies and procedures in a way that will comply with the General Data Protection Regulation.

Users should also take care with how they handle and disclose their Personal Information and should avoid sending Personal Information through insecure email. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.

CHOICES ABOUT HOW WE COLLECT, USE AND DISCLOSE USER’S PERSONAL INFORMATION
We strive to provide user with choices regarding the Personal Information user provide to us:

• User can choose not to provide us with certain Personal Information, but that may result in being unable to use certain services;
• When a user registers with us, they may be given a choice as to whether they want to receive email messages, newsletters or advertising material about updates, improvements, special offers, or containing special distributions of content by us. If initially consented, and later on decided, that they no longer want to receive commercial or promotional emails or newsletters from us, they will need to avail themselves of the unsubscribe mechanism set out in the applicable communication. It may take up to seven days for us to process an opt-out request. We may send other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering the opportunity to opt out of receiving them as these will be related directly to user’s relationship with us;
• If users provide Personal Information, they may terminate the relationship with us at any time as per the provision of the between us agreement or engagement. If they choose to do so, Personal Information will be deleted in accordance with our retention policy.

User’s Rights Related to Personal Information

Subject to the provisions of the General Data Protection Regulation, users have certain rights regarding the Personal Information we collect, use or disclose and that is related to them, including the right:

• To receive information on the Personal Information concerning the user and how such Personal Information is used (right to access);
• To rectify inaccurate Personal Information concerning them (right to data rectification);
• To delete/erase their Personal Information (right to erasure/deletion, “right to be forgotten”);
• To receive the Personal Information provided by them in a structured, commonly used and machine-readable format and to transmit Personal Information to another data controller (right to data portability);
• To object to the use of Personal Information where such use is based on our legitimate interests or on public interests (right to object); and in some cases, to restrict our use of Personal Information (right to restriction of processing). 

If we ask for consent to use Personal Information, the user can withdraw consent at any time.

They may, at any time, send us an e-mail at info@homemake.com.cy to exercise the above rights in accordance with the applicable legal requirements and limitations. If located in the European Economic Area, they have a right to lodge a complaint with the local data protection authority.

Note that some requests to delete certain Personal Information will require the deletion of user account as the provision of user accounts are inextricable linked to the use of certain Personal Information (e.g., e-mail address). Also note that it is possible that we require additional information from the user in order to verify authorization to make the request and to honor their request. 

CHANGES TO OUR PRIVACY POLICY
We may modify or revise our privacy policy from time to time. Although we may attempt to notify the user when major changes are made to this privacy policy.

If we change anything in our privacy policy, the date of change will be reflected in the “last modified date”. Users agree that they will periodically review this privacy policy and refresh the page when doing so. Agreeing to note the date of the last revision to our privacy policy. If the “last modified” date is unchanged from the last time they reviewed our privacy policy, then it is unchanged. On the other hand, if the date has changed, then there have been changes, and users agree to re-review our privacy policy. By continuing to use the Website subsequent to us making available an amended version of our privacy policy in a way that user can easily take notice of it, user thereby consent to such amendment.

ENFORCEMENT; COOPERATION
We regularly review our compliance with this privacy policy. Please feel free to direct any questions or concerns regarding this privacy policy or our treatment of Personal Information by contacting us through this Website at info@homemake.com.cy. When we receive a formal written complaint, it is our policy to contact the complaining party regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the collection, use and disclosure of Personal Information that cannot be resolved by an individual and us.

NO RIGHTS OF THIRD PARTIES
This privacy policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Website.

NO ERROR FREE PERFORMANCE
We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy.

CONTACT INFORMATION
Any questions regarding our privacy policy or information-handling practices, please contact us at info@homemake.com.cy

User may also contact us at Adamantiou Korai 72, Paralimni 5280, Cyprus telephone +357 70 001371