September 2023

Introduction 

This Privacy Policy describes how NOVICHENTO LIMITED (hereinafter the “Company”) collects, uses, and discloses certain personal information obtained through our public website at www.novicheto.com  or directly from you and/or through third parties.

The Company, with full respect to your rights and always in accordance with the GDPR Regulation, has established policies and procedures to comply with its obligations. This Policy has been drafted and is updated as necessary to ensure that the company will remain in compliance with the General Data Protection Regulation (EU) 2016/679 and the relevant local legislation (hereinafter the GDPR). 

This privacy policy explains in detail how we use your personal data. It describes what kind of data we collect, in what circumstances we may use your information, who we share your data with and how we protect your data. It applies to the services we provide to you directly or when you contact us through this website. It applies even if you are not one of our customers and you interact with us, such as by asking generally about our services.

Who We Are?

NOVICHENTO LIMITED (hereinafter the “Company”, “we”), is a limited liability company, incorporated under the Companies Law of the Republic of Cyprus, Cap. 113, under the given registration number HE444366. It was incorporated in 2023, having as main activities the vehicles rental and leasing. 

How do we collect/receive information?

• Directly from you and/or
• Through third parties and/or
• Through this website

Information Collection:

In general, you can our website maintaining your anonymity. Occasionally, however, we may need from you to provide personally identifiable information, such as your name, company, e-mail address, phone number address etc. (“Personal Information”). The purpose for requesting the particular info may involve, corresponding with and/or contacting you, fulfilling your requests, or otherwise to provide you with a subscription to a newsletter or publication, or to notify you about new services. Where applicable, we will differentiate between personal data fields that are optional and those that are mandatory in order for you to obtain the requested information.

Categories of Personal Information we collect:

• Information you provide us when you give your consent to the processing of your data or when you contact us or when you report a problem;
• Information you provide us with when you contact us through email or phone;
• Information you give us when you make a reservation;
• Information we receive when you link to us on our social media.
• Information you give us when you request cancellation and/or change to the dates of your booking,
• Information that is publicly available, such as on Social Media and the Internet (where you join us using Social Media).

Personal Information about you that you provide to us when you use the Site, such as when you make a reservation through our website, and/or when you make a reservation, and/or when you contact us through the Site and/or when you request information or otherwise provide us with your personal information. 

This information may include (but is not necessarily limited to) the following information and/or data:

• your full name;
• contact details such as address, telephone number and email address;
• date of birth;
• your driving license details;
• transaction information;
• receipts and invoices of your purchases;
• browsing data in our website if you have consented (see more in our Cookies Policy).;
• preference data – where you have consented;
• data obtained through cookies, where you have given us your explicit and informed consent;
• Location data – when you use the rented car.  – see Vehicle User Data Processing Policy
• Navigation history data – when you use the navigation services 

For this reason, you should ensure that the personal data you supply to us is accurate and complete.

Purpose for the processing of your Personal Information:

• to confirm and guarantee your reservation;
• modify or cancel your reservation; 
• exchange information with you in connection with your reservation (e.g., to provide you with information about your reservation, to answer your questions);
• to identify you;
• to prepare the rental agreement;
• to perform your payment invoices; 
• to manage possible claims such as 

• payment incidents that have led to legal proceedings,
• vehicle accidents or repeated damage caused by customers
• accidents or damage caused intentionally by the customer,
• use of our vehicles in breach of the general terms and conditions of vehicle rental.

• to manage possible fines;
• to make your browsing experience on our Website more convenient by customising your browsing experience (see the “cookies” section below);
• to provide you with information about services that may be of interest to you (see the “Marketing” section below);
• for the purposes of complying with our legal obligations;
• for statistical purposes. It should be noted that the collection of statistical data and/or the provision of such data to third parties is always performed in such a way that these data are not identifiable.

Legal bases for the Collection, process, disclosure and use of Personal Information:

The disclosure and transfer of personal data must meet the below circumstances, which are used in order to establish our legal basis:

• it is necessary in order for us to perform a contract between the individual and the Company; 
• it is necessary in order for us to take measures to enter into a contract with the individual where it has requested us to do so;
• it is necessary for us to establish, exercise or defend legal claims; or
• it is necessary for us in order to be in compliance with our legal obligations; or 
• if none of the conditions listed above apply, the individual has explicitly consented to the overseas transfer. 

Data Sharing:

our Company does not disclose your personal information to third parties. We may, however, share some of your personal information with our affiliated companies (providers) for purposes of responding to your requests or otherwise as required for the purposes described above.

List of recipients:

• Affiliated companies – service providers.
• Third parties such as authorities, partners and administrative staff (e.g., tax authorities, banking institutions, insurance agencies, etc.).
• Legal Successors– only in the event of a merger, divestiture, restructuring, reorganization, dissolution and/or sale and/or transfer of some or all of our assets may we disclose personal information to a purchaser or successor.

Transfer of Data to a Third Country:

Personal data transferred outside the European Union will be stored and processed by service providers, or agency offices for commercial and administrative purposes, to perform a contractual obligation we have with you and/or to provide you with information or services you have requested. We will take appropriate measures to protect your personal data. 

We will not transfer your personal data to a Third Country unless one of the following conditions applies:

• the EU Commission has decided that the country provides an adequate level of protection for your personal data; or
• the transfer of your personal data is subject to adequate safeguards, which may include Binding Corporate Rules or Standard Contractual Clauses approved by the EU Commission; or
• one of the GDPR derogations to transfer personal data to a Third Country applies.

Marketing – advertising

We will only use your personal information for the provision of our services, including any notification, for example changes to any product and/or service we offer.

For advertising purposes, and only if you have provided to us your explicit and freely given consent, we will contact you in order to inform you about services and/or products that we or other third parties may offer and which may be interesting to you.

If you wish to withdraw your consent, you will be provided with an automated way to opt-out of all emails and/or mobile phone messages sent by us. In such a case, please follow the instructions from the email you received to do so.

Retention period:

We implement a specific policy to keep records containing personal information and/or data, within the framework of Union or national law and only as required for the purposes for which they have been collected.

We assure you that the data we collect will be destroyed once the purpose for which they have been collected has been fulfilled and we have no legal obligation to retain them.  If the processing is based on your consent granted to us for the purpose of ongoing recurring processes, such as receiving notifications from us about new products and/or offers, then we will use this data until you withdraw your consent. should be mentioned that actions based on your consent prior to its revocation remain lawful as the revocation of consent is not retroactive.

Individual’s Rights:

The Individuals have the following rights:

• Right of access – request access to any personal data we hold about them;
• Right of rectification -have any personal data which we hold about them which is inaccurate or incomplete rectified;
• Right to be forgotten – have personal data erased; 
• Right to restriction of processing – have the processing of individual’s personal data restricted;
• Right of portability – To be provided with the personal data that the individual has supplied to us in a portable format that can be transmitted to another organisation without hindrance; 
• Right to object – object to certain types of processing, including processing based on legitimate interests, automated processing (which includes profiling) and processing for direct marketing purposes; and
• Right to object to automated processing, including profiling -not be subject to a decision that is based solely on automated processing which produces a legal effect or which has a similar significant effect for the individual. 

If you wish to exercise any of the rights set out above you should contact us directly by using the contact details as described below.  Should be noted that some of these rights are restricted in some circumstances. In this case, we will inform you in writing of the reasons for not complying or fully complying with your request.

Cookie policy                                                                                                               

A cookie is a small file which asks permission to be place on your computer’s hard drive. For full details of our cookie policy please refer to our main internet site or our Cookies Policy.

Personal Data Security:

Company has taken adequate technical and organizational security measures to ensure high protection of Personal Data from any unauthorized access or disclosure. In addition, it is committed to review and revise these measures in due course so as not to compromise the protection of Personal Information held by it. Any changes, we commit that they will always be made in accordance with the provisions of the GDPR Regulation and relevant Directives and national laws. Finally, when and where it deems necessary, and if it requires security of your data and rights, it will conduct risk assessments, update and/or modify policies and procedures in order to comply with the GDPR.

Links (Links):

This website may contain links to other websites. It is underlined that in such a case Company is not responsible for the privacy practices of other websites. This privacy policy applies to the information collected solely by the Company. The decision to use links is exclusively under your control so we encourage you to be careful and read the privacy policy of each website you may link to.

Use of Social Media:

The Company does not exercise control in any way over the data that are subsequently transmitted and/or that may be collected and/or processed by any of the available social networks with which you may search for us and/or connect with us, nor can it control in any way the collection and/or processing of such data. To this end, we encourage you to carefully read the privacy policy of the respective social network, which provides information on the collection and processing of your data by the respective social networks, as well as information on the rights and available privacy settings. More information can be found in our Cookies Policy.

Child Protection:

The Company clarifies that our services do not apply to persons under the age of 18. Therefore, we clearly state that we do not collect and do not wish to collect and/or process data of minors to our knowledge.

Contact:

Company is a Data Controller and you can contact us at any time using the contact details below:

Tel: +357 95197929 or +357 94043290

Email: info@novichento.com 

Website:  www.novichento.com Address: 7 Kato Zodias, Mesa Geitonia, 4007 Limassol Cyprus.

How you can petition for complaints

It is very important for the principles of privacy to be followed and we should take all the appropriate measures to avoid any breach or loss of these data. 

The personal data you disclose to us, we ensure that they are saved in a platform which is protected with additional security factors.

Any breach of the GDPR and/or other relevant Data Protection Acts will be taken seriously and if you consider that the data protection principles have not been followed in respect of personal data about yourself or others you have the right to lodge a complaint with the relevant data protection supervisory authority.

Our Protection Supervisory Authority is the Personal Data Protection Bureau (Independent Supervisory Authority for the Protection of Individuals). If you have any issues with our processing of your personal data and would like to make a complaint, you may contact the Personal Data Protection Bureau on (+357) 22 818 456 or at 1 Iasonos, 1082 Nicosia, Cyprus.

Revisions to this Privacy Policy:

Company reserves the right to change this Privacy Policy from time to time. Please check the Privacy Policy frequently and particularly before you submit additional personal information via the Website. All revisions to this Privacy Policy will be posted on the web site via a link from the homepage. We also display the effective date of the Privacy Statement on the top of this page.