Privacy Policy

Welcome to the privacy policy (the “Privacy Policy”) of:
Logicom Cyprus Marathon which is made up of the following legal entities

• GK Running In Cyprus Ltd (company number ΗΕ 386293)

• logicomcyprusmarathon.com
• runningincyprus.com
• cyprusmarathon.com
• cypruswinerun.com
• https://registration.mylaps.com/cyprus-marathon
• https://register-sportsincyprus.com/cyprus-marathon/
• and/or any of the other websites that are operated by the GK Running in Cyprus Ltd, (collectively the “Site”), regardless of where you visit it from, and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION

1. IMPORTANT INFORMATION AND WHO WE ARE
2. PURPOSE OF THIS PRIVACY POLICY
3. 1. 1. This Privacy Policy aims to give you information on how We collect and process your personal data through your use of the Site, including any data you may provide through the Site for the reasons specified in paragraph 3.1.1 below.

1. We may collect data relating to children for the reasons detailed in paragraph 4.4 below. For more information on our policy on children’s personal data, please see paragraph 4.12.

1. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice We may provide on specific occasions when We are collecting or processing personal data about you so that you are fully aware of how and why We are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

1. CONTROLLER
   1. GK Running in Cyprus Ltd is the controller and responsible for the Site.

1. You have the right to make a complaint at any time to the Information Commissioner’s Office (the “ICO”). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please Contact Usin the first instance.

1. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
   1. It is important that the personal data We hold about you is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us.

1. THIRD-PARTY LINKS The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Site, We encourage you to read the privacy policy of every website you visit.

1. THE DATA WE COLLECT ABOUT YOU
   1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

1. We may collect, use, store and transfer different kinds of personal data about you which We have grouped together as follows:
   1. “Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, photographs, vehicle registration number(s), bib /race number, age, gender, qualifications, professional membership details and insurance details.

1. “Contact Data” includes billing address, residential address, delivery address, email address, social media handles and telephone numbers.

1. “Financial Data” includes bank account and payment card details.

1. “Transaction Data” includes details about payments to and from you and other details of products and services you have purchased from us.

1. “Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, full ‘Uniform Resource Locators’ clickstream to, through and from the Site (including date and time) and other technology on the devices you use to access the Site.

1. “Profile Data” includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, performance, results and times at our events, products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, mouse-overs and methods used to browse away from the page).

1. “Usage Data” includes information about how you use the Site, products and services.

1. “Marketing and Communications Data” includes your preferences in receiving marketing from us and Our third parties and your communication preferences.

1. We also collect, use and share Aggregated Datasuch as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if We combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this Privacy Policy.

1. We may also collect personal data that includes “Sensitive” or “Special Categories” of personal data, such as: dietary requirements, details about your race or ethnicity, information about your health, genetic and biometric data and certain medical information (including whether or not you are a wheelchair user).
2. IF YOU FAIL TO PROVIDE PERSONAL DATAWhere We need to collect personal data by law, or under the terms of a contract We have with you and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with goods or services). In this case, We may have to cancel a product or service you have with Us but We will notify you if this is the case at the time.
3.  
4. HOW IS YOUR PERSONAL DATA COLLECTED?
   1. We use different methods to collect data from and about you including through:
      1. Direct interactions. You may give Us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with Us by post, phone, email or otherwise. This includes personal data you provide when you:
         1. apply for Our products or services;

1. create an account on the Site;

1. subscribe to Our service or publications;

1. request marketing to be sent to you;

1. apply to participate in one of our Events;

1. volunteer in some capacity at one of Our events;

1. sign up to Our educational or charitable programmes;

1. enter a competition, promotion or survey; or

1. give Us some feedback.

1. Automated technologies or interactions. As you interact with the Site, We may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites. Please see Our cookie policy(the “Cookie Policy”) for further details.

1. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks, technical, payment and delivery services, data brokers or aggregators and publicly available sources such as Registrar of Companies. Please Contact Us to find out more about the various third parties and public sources from which We may receive personal data about you.

1. HOW WE USE YOUR PERSONAL DATA
   1. We will only use your personal data when the law allows us to. Most commonly, We will use your personal data in the following circumstances:
      1. Where We need to perform the contract We are about to enter into or have entered into with you.

1. Where it is necessary for Our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests.

1. Where We need to Comply with a Legal or Regulatory Obligation.

1. Please Contact Usto find out more about the types of lawful basis that We will rely on to process your personal data.

1. We consider registering, participating or being informed for our event as a consent on a legal basis for processing the personal data you provide to us. You have the right to withdraw consent to marketing at any time by Contacting Us.

1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
   1. We have set out below, in a table format, a description of all the ways We plan to use your personal data, and which of the legal bases We rely on to do so. We have also identified what Our Legitimate Interests are where appropriate and the period for which we retain your personal data. For the avoidance of doubt, please be aware that where we use a specific type of personal data for more than one reason and there is a conflict between the retention period for each such use in the table below, the longest retention period shall prevail.

1. Note that We may process your personal data for more than one lawful ground depending on the specific purpose for which We are using your data. Please Contact Usif you need details about the specific legal ground We are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of Legitimate InterestRetention period (not exceeding)To apply to participate, or participate, or to organise a team, in any of Our events(a) Identity Data
(b) Contact Data
(c) Transaction Data
(d) Technical Data
(e) Profile Data
(f) Marketing and Communications Data(a) Performance of a Contract with you
(b) Legitimate Interests (We need this data to be able to allow you to participate in Our events and to stage Our events).6 years from last application to participateTo facilitate and publish the results of Our events(a) Identity Data
(b) Profile Data(a) Legitimate Interests (We need the ability to publish and store the results, rank individuals, challenge results after the Specific Event and keep a historic log of this data all for the purpose of staging the event(s) and for archival and historic research. This also allows participants to rank themselves against other participants).In perpetuityTo televise, film and/or otherwise record Our events and to take photographs and record footage of Our events(a) Identity Data(a) Legitimate Interests (We need the ability to publish, display, sell and distribute Our events by means of film, television, radio, print media, internet, publicity material or any other media now or in the future).In perpetuityTo invite you to participate, and for you to participate, in Our Hospitality(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data(a) Performance of a Contract with you.
(b) Legitimate Interests (We need this data to be able to give you the option to attend, and to provide you with, high-quality hospitality).3 years since the last invitation or purchase, whichever is laterTo volunteer for Our events(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data(a) Performance of a Contract with you
(b) Legitimate Interests (We need this data to be able to allow you to participate in Our events and to stage Our events).
(c) Necessary to Comply with a Legal or Regulatory Obligation (including security and safety at Our events and tax purposes).3 years since your last application to volunteerTo provide your services on a casual labour basis to Us(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Profile Data
(f) Marketing and Communications Data(a) Performance of a Contract with you
(b) Legitimate Interests (We need this data to be able to allow you to participate in Our events and to stage Our events).
(c) Necessary to Comply with a Legal or Regulatory Obligation (including security and safety at Our events and tax purposes).7 years since you applied for your last roleTo be included on Our media lists(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data(a) Legitimate Interests (We need this data to be able to enable Our events to be covered in the media).3 yearsTo be a partner, sponsor or supplier or potential partner, sponsor or supplier of or to Us or Our events(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data(a) Performance of a Contract with you (as Our partner, sponsor or supplier)
(b) Legitimate Interests (We need this data to be able to contact you about becoming a partner, sponsor or supplier to allow you to become officially associated with Us or Our event(s)).
(c) Necessary to Comply with a Legal or Regulatory Obligation (including for tax purposes).6 years after the end of any contract (if any) or 6 years from the last correspondence about being a potential partner, sponsor or supplierTo be a medical professional including doctor, podiatrist and physiotherapist at one of Our events(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data(a) Performance of a Contract with you
(b) Legitimate Interests (We need this data to be able to allow you to provide your services at Our events, to ensure that you are adequately qualified and to ensure that We have the requisite number of medical professionals at Our events).
(c) Necessary to Comply with a Legal or Regulatory Obligation (including for tax and insurance purposes).6 years from the date of the last event you assisted withTo be a Golden Bond, Silver Bond or other Charity contact or to apply to be part of Our charity ballots(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data(a) Performance of a Contract with you
(b) Legitimate Interests (We need this data to be able to provide you with the benefits of being a bond holder or charity contact and to ensure that you remain on the waiting list if you are on such list).

6 years after the expiry of your Bond or last application to be an official charity

For as long as those remain on the waiting list wish to remain there

To attend one of Our events in any capacity that requires photographic accreditation (not otherwise dealt with in this table)(a) Identity Data
(b) Contact Data(a) Legal Obligation
(b) Performance of a Contract with you
(c) Legitimate Interests (We need this for security reasons).6 years after the last time you were accreditedTo apply to participate in our events if you are under 13 years of age(a) Identity Data
(b) Contact Data(a) Consent (parental consent either obtained by Us or via a third party).
(b) Legitimate Interests (to allow minors to participate in Our events, please see paragraph 4.12 below).5 years from last application to participate or until you reach the age of 13, whichever occurs soonerTo register you as a new customer (not otherwise dealt with in this table)(a) Identity Data
(b) Contact Data(a) Performance of a Contract with you
(b) Legitimate Interests (to provide you with customer services).3 years from last registration as a customer or last interaction with Us as a customer, whichever is laterTo process and deliver your order including:
(a) Manage payments, fees and charges; and
(b) Collect and recover money owed to Us(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data(a) Performance of a Contract with you
(b) Necessary for Our Legitimate Interests (to recover debts due to Us)
(c) Necessary to Comply with a Legal or Regulatory Obligation (including for tax and consumer protection purposes).6 years from order completionTo manage Our relationship with you which will include: (a) Notifying you about changes to Our terms or Privacy Policy
(b) Asking you to leave a review or take a survey
(c) dealing with any complaints and responding to feedback(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data(a) Performance of a Contract with you
(b) Necessary to Comply with a Legal or Regulatory Obligation
(c) Necessary for Our Legitimate Interests (to keep Our records updated and to study how customers use Our products/services)6 years from last correspondenceTo enable you to partake in a prize draw, competition or complete a survey(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data(a) Performance of a Contract with you
(b) Necessary for Our Legitimate Interests (to study how customers use Our products/services, to develop them and grow Our business)3 years from prize draw, competition or surveyTo administer and protect Our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity Data
(b) Contact Data
(c) Technical Data(a) Necessary for Our Legitimate Interests (for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to Comply with a Legal or Regulatory Obligation3 years from collection of dataTo deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data
(f) Technical Data(a) Necessary for Our Legitimate Interests (to study how customers use Our products/services, to develop them, to grow Our business and to inform Our marketing strategy)3 years from collection of dataTo use data analytics to improve the Site and Our products/services, marketing, customer relationships and experiences(a) Technical Data
(b) Usage Data(a) Necessary for Our Legitimate Interests (to define types of customers for Our products and services, to keep the Site updated and relevant, to develop Our business and to inform Our marketing strategy)3 years from collection of dataTo make suggestions and recommendations to you about goods or services that may be of interest to you (including where you have applied via the ballot for a place at one of Our events or where your image is captured by our official photographer at one of Our events)(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data(a) Necessary for Our Legitimate Interests (to develop Our products/services and grow Our business and to provide you with the opportunity to purchase goods that commemorate your participation in one of Our events (such as an official photograph))3 years from last unsuccessful ballot application or 3 years from last participation in one of Our events, whichever is laterFor event logistics and operational purposes (including emergency service access routes, personal care plans and public access routes)(a) Identity Data
(b) Contact Data(a) Necessary for Our Legitimate Interests (for ensuring that the event logistics are in place to ensure successful staging of Our events)
(b) Necessary to Comply with a Legal or Regulatory Obligation (safety and security and insurance)3 years from the event to which the data relates

1. AUTOMATED DECISION MAKINGWe use your personal data to make the following automated decisions:
   1. Competitions: We may, from time to time, run competitions where each participant’s personal data is uploaded to Our database and a successful participant is automatically selected at random;

1. Seeding: Start times or start positions at Our events may be dependent upon estimated finishing time. In this case each participant’s personal data is uploaded to Our database and a participant’s staring place/group is selected by automated means.

1. MARKETINGWe strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

1. PROMOTIONAL OFFERS FROM US
   1. We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what We think you may want or need, or what may be of interest to you. This is how We decide which products, services and offers may be relevant for you (We call this marketing).

1. You will receive marketing communications from Us if you have requested information from Us or purchased goods or services from Us or if you provided Us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

1. THIRD-PARTY MARKETINGWe will never share any of your details with any third-party that might use your details for marketing purposes.

1. OPTING OUT
   1. You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting Usat any time.

1. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service purchase, product/service experience or other transactions.

1. COOKIESYou can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly. For more information about the cookies We use, please see Our Cookie Policy.

1. CHANGE OF PURPOSE
   1. We will only use your personal data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact Us.

1. If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the legal basis which allows Us to do so.

1. Please note that We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. CHILDREN’S DATA
   1. We may collect and process the personal data of children below the age of 13 for the purposes of administering the following areas of our business, in which case we will always ensure that consent is given or authorised by the holder of parental responsibility over that child:
      1. Events in which children may participate. We require the child’s details in order for them to participate;

1. To televise, film and/or otherwise record Our events and to take photographs and record footage of Our events; and

1. To facilitate and publish the results of Our events.

1. DISCLOSURES OF YOUR PERSONAL DATA
   1. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.4 above.
   2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow Our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with Our instructions.

1. INTERNATIONAL TRANSFERS
   1. We might use your personal data with third-parties that will assist us in providing you with the service that you signed for.

1. DATA SECURITY
   1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Our instructions and they are subject to a duty of confidentiality.

1. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.

1. DATA RETENTION
   1. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

1. We will only retain your personal data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

1. To determine the appropriate retention period for personal data, We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal requirements.

1. Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4.4 above.

1. By law We have to keep basic information about Our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for six years after they cease being customers for tax purposes.

1. In some circumstances you can ask Us to delete your data: see [Request erasure] below for further information.

1. In some circumstances We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case We may use this information indefinitely without further notice to you.