April 19, 2022
As of May 25th, 2018, the General Data Protection Regulation (EU 2016/679), also known as the GDPR has come into effect. The GDPR strengthens the legal framework for the protection of data subjects regarding the processing of personal data in the European Union.
In addition to the above, law 125(I)/2018 which provides for ” The Protection of Individuals Against the Processing of Personal Data and the Free Circulation of this Data” is also in force and is being implemented in adaptation and harmonization with the GDPR. The Democratic Alignment, with respect to personal data, complies with the GDPR. In the context of its activity and purpose, the Democratic Allingment takes all the provided and available technical and organizational measures in accordance with the provisions of the GDPR, and the legislation in general.
At the Democratic Alignment, we are committed to protect the privacy of the information and personal data you entrust to us and manage your personal information in a fair and transparent manner. The following privacy statement applies to the personal data processed by the Democratic Alignment, a registered political party in Cyprus with registration number 18, based at 58 Digeni Akrita avenue, 1061 Nicosia.
The privacy statement describes the type of personal data or information we collect from you, when and why this information is used and to whom it is provided. In addition, it indicates your rights in relation to your data, as well as the persons you may contact for additional information or any questions.
You can read more about this privacy statement by following the paragraphs below:
1. What type of personal information we hold about you?
2. What type of personal data is collected and how?
3. How we use this information about you
4. The legal bases we use to process your personal data
5. With whom we share your information
6. Protection of your personal information
7. How long we keep your information
8. Your rights
9. Right to file a complaint
10. Changes to this privacy statement.
The Democratic Alignment collects various types of personal data about you depending on the purpose for which we process it. These are:
✓ Identification information (name, surname, ID number etc.)
✓ Demographic data (address, place of residence etc.)
✓ Professional data
✓ Education data
The personal data that we collect, and process is limited to what is necessary for a specific purpose and specific legal basis. Our aim is to provide to you the best and personalized service, in the context of political communication as well as information regarding activities and events of the Party.
Any reference to “Our Website” in this policy, we refer to the party’s Website, www.depa.cy.
The personal data we may collect, without limitation are the following:
your name, date of birth, ID number, profession, home address, email address, telephone numbers, the IP address of your computer, the type and language of your browser, your access times, complaints details and other similar information.
Your personal data is collected:
✓ By submitting the member’s application form (in paper or electronically);
✓ By registering (personally or electronically) to receive information material by our Party;
✓ By participating in activities and/or events of the Party;
✓ By submitting personal or electronic applications and CVs for recruitment to the Party.
We do not collect information about you that may be included in “sensitive” or “special categories” of personal data, such as details about your health (for example, in relation to life and health issues) or your racial or ethnic origin. Please note that the processing of sensitive personal data is not permitted by law, and your explicit consent is required in case we ever need to collect sensitive personal data.
We understand the importance of protecting children’s privacy. Our website as well as the membership registration process are not designed or intended for children. Intentional collection and storage of data for children is not part of our policy. For the purposes of this Privacy Statement, “children” are persons under the age of fourteen.
We will only process your personal data when the law allows it. We will usually use your personal information in the following cases:
✓ For your registration as a member of the Democratic Alignment
✓ For the evaluation of your CV for your recruitment in the Party
✓ For the concluding agreements with partners and suppliers
✓ For our compliance with a legal obligation
✓ To process your requests
✓ For your participation in Party events
You may withdraw your consent to any such processing at any time by contacting us at firstname.lastname@example.org or by using the “Unsubscribe” function, which is available in all emails sent for informational purposes.
Please note that any processing of personal data prior to the withdrawal of your consent is not affected.
The extent to which we process any sensitive personal data relating to you for any of the above purposes, we will do so because:
• you have given us your explicit consent to the processing of this data;
• processing is necessary to meet our obligations under employment, or social security legislation;
• the processing is necessary for the establishment, exercise, or support of legal claims, or
• you have made your data publicly available.
Use of personal data collected through our Website
In addition to the above purposes regarding the operation of the Party, we may also use your personal data collected through our Website:
• for the management and improvement of our website;
• to customize the content of our website to include information regarding announcements, information, actions, and activities that may be of interest to you;
• to manage and respond to any request you submit through our Website.
The legal bases on which we use for the processing of personal data are:
✓ When you have consented to the processing of your data, for one or more purposes.
✓ When processing is necessary to execute a contract to which you are a part of.
✓ When processing is necessary for our compliance with our legal obligation.
✓ When processing is necessary to safeguard the vital interest of the data subject or other natural person.
✓ When processing is necessary for the performance of a duty performed in the public interest or in the exercise of public authority entrusted to us.
✓ When the processing is necessary for the purposes of the legitimate interests pursued by the Party if their interests and fundamental rights and freedoms as data subjects prevail over them.
Within the framework of the processes assigned to them by the Democratic Alignment itself as the Controller and according to the GDPR either under a contract or other legal act that connects them, the employees of the Democratic Alignment have access to your personal data, as the Processors.
The Democratic Alignment in the context of political communication, indicative of the periods of any kind of electoral process, has the right to disclose your personal data to various third-party recipients, who are directly ideologically affiliated with the Party and have the same programmatic principles and political positions. Such are the candidates for the position of President of the Party, candidate members for the organizational positions of the Party, the candidates for members of the Cyprus Parliament and candidates for members of the European Parliament, the candidates for Mayors, the candidates for the Local Government elections and others.
Further details on the transfers described above and the adequate safeguards used by us (including copies of relevant agreements) can be made available to you by contacting the Democratic Alignment Data Protection Officer on 22 270007 or by email at email@example.com.
We have implemented several physical, electronic, and administrative measures to ensure that your personal data is secure, accurate and up to date. These measures include:
❖ Education and training of the relevant staff to ensure they are aware our privacy obligations when handling personal information.
❖ Administrative and technical controls to restrict access to personal data based on a “need to know” basis.
❖ Technological security measures, including firewalls, encryption, and antivirus software.
❖ Physical security measures, such as staff security passes to access our premises.
The Democratic Alignment processes your personal data only for the period required for the purposes of the processing. However, we must retain this personal data for the entire period from the registration and the provision of your consent and for the entire duration that you retain the membership, while in case of loss of this status, they are kept for an additional 7 years, and this in support of the legitimate interests of the Party.
You have various rights in relation to your personal information. In particular, you have a right to:
✓ Right to Information (Article 12): You have the right to concise, transparent, understandable, and easily accessible information without delay and in any case a response within one month of receipt of the request.
✓ Right to Information upon Obtaining Consent (Articles 13 and 14): Upon obtaining consent, Democratic Alignment will inform you about the purposes of collecting your personal data during their storage period, to whom the data and information will be communicated their processing.
✓ Right of Access (article 15): You have the right to be fully informed about the personal data that concern you and are processed in Democratic Alignmnet. You can request a copy of your personal data and we are obliged to deliver it to you within a specified period.
✓ Right to Rectification (Article 16): You have the right to request a correction or modification or supplement of your personal data that we hold and process either because it is incomplete or because it is incorrect.
✓ Right to Erasure “right to be forgotten” (article 17): You have the right to request from the Party the deletion of personal data that concern you directly and without delay. Your right will be satisfied unless the Party, as the Controller, has a superior legal interest.
✓ Right to Restriction of Processing (Article 18): You have the right to request that we suspend the processing of your personal data when one of the following applies:
• Your personal data is not accurate.
• Processing is illegal and you oppose the deletion of personal data and ask instead to restrict their processing.
• They are no longer required for processing, but the data is required by you to establish, exercise, or support legal claims.
• When you have objections to their processing, and you are waiting for the verification whether the legal reasons put forward by the Party prevail over your own reasons.
✓ Right of Disclosure (Article 19): You have the right to be informed about the information of third parties by the Party, to whom your personal data were disclosed, in cases of correction and / or deletion.
✓ Right to data portability (Article 20): You have the right to receive your data in a commonly used format and transfer it to another organization (if this is technically possible).
✓ Right to Object (article 21): You have the right to object to the processing of the data concerning you unless we as Democratic Alignment have a superior legal interest in the continuation of the processing.
✓ Right to Non-Automated Decision Making (Article 22): You have the right not to be subject to decisions made solely based on automated processing including profiling.
At any time, you have the right to terminate the Party to the Data Protection Commissioner. You also have the right to withdraw your consent to the processing of your personal data for specific purposes at any time. Any revocation of consent will not affect the legality of the processing based on your consent before it is revoked by you.
Some of the rights described above may not be exercised if there are reasons as stated in Article 23 of the GDPR.
You will not have to pay any fees to access your personal data (or to exercise any of your rights). However, we may charge a reasonable fee if your request for access is obviously unfounded or excessive. Otherwise, we may refuse to comply with your request in such circumstances.
When submitting your request and in order to help us verify your identity and therefore secure your right of access (as well as your other rights), we may ask you for specific information as an appropriate security measure to ensure that your personal data will not be disclosed to a person who is not entitled to receive it.
To exercise any of your rights or if you have any other questions regarding the use of your personal data by us, you may email at firstname.lastname@example.org or mail us at:
Data Protection Officer,
58 Digenis Akritas avenue,
1061 Nicosia, Cyprus.
You may also use the above contact details to file a complaint regarding the protection of your personal data.
If you are not satisfied with the way we handled your personal data or any questions or requests you have made to us, you have the right to file a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus. If you would like to contact the Commissioner’s office, please contact us.