Privacy Policy
1. Introduction
This Privacy Policy outlines how FINGRAM CYPRUS LTD (hereinafter referred to as the “Centre,” “we,” “us,” or “our”) collects, uses, and safeguards your personal data in accordance with the General Data Protection Regulation (GDPR), the laws of Cyprus, and other applicable regulations. We are committed to protecting the privacy of our students, teachers, employees, and visitors to our website and applications.
2. Definitions
- Website Administration – authorised personnel managing the website on behalf of FINGRAM CYPRUS LTD.
 - Personal Data – any information that directly or indirectly relates to an identified or identifiable natural person.
 - Processing of Personal Data – any operation performed on personal data, including collection, recording, organisation, storage, use, and transfer.
 - Cookies – small data files stored on a user’s device to help improve website functionality.
 - IP Address – a unique address assigned to a device on a network.
 - Legal Representatives – persons authorised to act on behalf of minors.
 
3. Data collection
We may collect the following categories of personal data:
- First name, last name, age (if required for events)
 - Contact details (email address, phone number)
 - Residential address (for sending materials or organizing offline events)
 - Payment information (to pay for services)
 - IP address and device data (for users of the online platform)
 - Educational history (if required for the program)
 - Cookies to analyze site performance and improve user experience
 
Automatically collected data includes:
- IP address
 - Browser information
 - Access time
 - Previous page URL
 
4. Data processing purposes
We process your personal data for the following purposes:
- Registering for services and managing visits
 - Providing offline and online financial literacy services
 - Organizing interaction between administrators and visitors
 - Payment for services and account administration
 - Fulfilment of legal obligations
 - Sending information about new services and events (with your consent)
 
5. Reasons for processing
Data processing is based on the following legal bases:
- The need to fulfill the contract
 - Compliance with legal obligations (e.g. accounting and tax reporting)
 - The legitimate interests of the school (improving the quality of service)
 - Your consent to send newsletters and marketing messages
 
6. Data retention periods
Personal data is stored only for the time necessary to fulfill the purposes of processing or as required by law. Data related to services may be stored to confirm the completion of services.
7. Data subjects' rights
You have the right to:
- Get access to your personal data
 - Correct inaccurate data
 - Delete your data (“right to be forgotten”) unless this is contrary to legal obligations
 - Restrict data processing
 - Object to data processing
 - Transfer your data to another service at your request
 - Withdraw consent to data processing at any time
 
8. Data protection
We take all necessary technical and organizational measures to protect your data from unauthorized access, alteration, disclosure or destruction. Protection includes the use of encryption, regular software updates, and access control.
9. Data transfer to third parties
Your personal data may be shared with the following third parties:
- Payment services for processing payments
 - Online learning management platforms
 - Legal and accounting companies to comply with legal obligations
 - Government agencies, if required by law
 
Data is not transferred to third parties without your consent, except as required by law.
10. Juvenile policy
Minors' personal data is processed only with the consent of their parents or legal representatives. We strongly encourage parents to participate in their children's education and monitor their online activities.
11. Cookies
We use cookies to optimize the site's performance. Cookies help us remember your preferences, analyze user behavior, and improve our service. You can disable cookies through your browser settings, but this may affect the functionality of the site.
12. Data transfer outside the EU
If we transfer data outside the European Economic Area, we ensure that data recipients provide a level of protection equivalent to that applicable in the EU.
13. Activity logs and analytics
We may use activity logs to analyze site usage, detect crashes, and ensure security. This data is used to improve the functionality of the site and prevent security risks.
14. Data retention periods
Your personal data will be kept for as long as is necessary for data processing purposes or to comply with legal obligations. After achieving the goals, the data will be deleted or anonymized, unless otherwise provided for in legislation.
15. Complaints and data breaches
If you have any complaints about the processing of your data, you can contact our data protection officer. In the event of a personal data leak, users will be notified within a reasonable time and the necessary measures will be taken to minimize the consequences.
16. The rights and obligations of the parties
Administration rights:
- Modify, remove, or block content that violates laws or site policies
 - Monitor user activity to ensure safety, prevent fraud and protect school interests
 - Restrict access to site features to users who violate the terms of use
 
User responsibilities:
- Provide accurate information when registering and using the site
 - Not to use the site for illegal activities or to violate the rights of other users
 - Keep your login details confidential
 
17. Limitation of liability
We are not responsible for:
- Any loss or damage incurred by the user as a result of using the site or its services
 - Links to third party sites provided on our site. We do not control and are not responsible for their content and privacy policies
 - Interruption of access to the site due to technical failures or force majeure
 
18. Dispute resolution
All disputes arising from the relationship between the user and the site administration will be resolved in the Arbitration Court of Nicosia, Cyprus. We reserve the right to settle disputes out of court in accordance with Cyprus law.

