Privacy Policy

1. Introduction

This Privacy Policy explains how PELMENZILLA LTD collects, uses, discloses and protects personal data when you visit pelmenzilla.com, communicate with us or otherwise interact with us in connection with our business.

PELMENZILLA LTD processes personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, or “GDPR”) and applicable data protection law in the Republic of Cyprus.

2. Data Controller

The controller responsible for the processing described in this Privacy Policy is:

PELMENZILLA LTD
Company Registration No. HE 457829
5, A.G. LEVENTI, THE LEVENTIS GALLERY TOWER, Fl.: 13th, Apt.: 1301, 1097, NICOSIA, Cyprus
Email: [email protected]

3. Scope of This Policy

This Privacy Policy applies to:

• visits to pelmenzilla.com and its public pages;
• technical processing required to deliver and secure the website;
• business enquiries and other messages sent to [email protected];
• communications and records created as a result of those enquiries.

This website does not provide user accounts, online purchases or a server-based contact form.

4. Personal Data We Process

4.1 Technical and Usage Data

When you access the website, our hosting, content delivery and security providers may process technical data required to deliver and protect the service. This may include:

• Internet Protocol address;
• date and time of a request;
• requested page or file;
• referring page;
• browser type and version;
• operating system and device information;
• language and approximate location derived from an IP address;
• network, performance and security events;
• information used to detect malicious traffic, abuse and automated requests.

4.2 Communications Data

If you contact us by email, we may process:

• your name;
• your email address;
• your organisation and professional role;
• the content of your message;
• files or information you choose to attach;
• subsequent correspondence and records of our response.

Please do not send sensitive personal data unless it is necessary for your request and we have agreed to receive it.

4.3 Cookie and Similar Technology Data

The website does not use analytics, advertising or behavioural profiling cookies as of the effective date of this Policy. Strictly necessary technologies may be used by our hosting and security providers to deliver the website, prevent abuse and maintain security. Further information is available in our Cookie Policy.

5. How We Obtain Personal Data

We obtain personal data:

• directly from you when you send us an email or other communication;
• automatically from your browser or device when it requests website content;
• from hosting, security and IT providers acting on our behalf;
• from professional advisers or public authorities where permitted by law.

6. Purposes and Legal Bases

We process personal data for the following purposes:

6.1 Delivering and Securing the Website

We process technical data to display website content, maintain availability, diagnose errors, prevent abuse and protect the website and our systems.

The legal basis is our legitimate interest in operating a secure and reliable corporate website under Article 6(1)(f) GDPR.

6.2 Responding to Enquiries

We process communications data to review and respond to company, project and business enquiries.

The legal basis is taking steps at your request before entering into a contract under Article 6(1)(b) GDPR and our legitimate interest in managing business communications under Article 6(1)(f) GDPR.

6.3 Managing Business Relationships

Where an enquiry develops into a business relationship, we may process related communications and records to administer that relationship, perform agreed services and maintain appropriate business records.

The legal basis is performance of a contract under Article 6(1)(b) GDPR, compliance with legal obligations under Article 6(1)(c) GDPR and our legitimate interests under Article 6(1)(f) GDPR.

6.4 Legal Compliance and Protection of Rights

We may process personal data to comply with law, respond to lawful requests, prevent fraud and establish, exercise or defend legal claims.

The legal basis is compliance with legal obligations under Article 6(1)(c) GDPR and our legitimate interest in protecting the Company and its rights under Article 6(1)(f) GDPR.

7. Automated Decision-Making

We do not use personal data collected through this website to make decisions based solely on automated processing that produce legal or similarly significant effects.

8. Sharing Personal Data

We may disclose personal data to the following recipients where necessary:

• website hosting, content delivery and security providers, including Cloudflare;
• email, IT, storage and technical support providers;
• professional advisers, including legal, accounting and compliance advisers;
• insurers, auditors and business service providers;
• courts, regulators, law enforcement bodies and other public authorities where disclosure is required or permitted by law;
• parties involved in a merger, reorganisation, financing, acquisition or transfer of all or part of our business, subject to appropriate confidentiality and data protection measures.

Service providers are authorised to process personal data only for the services they provide to us and under appropriate contractual obligations.

We do not sell personal data.

9. International Transfers

Some service providers may process personal data outside Cyprus or the European Economic Area.

Where personal data is transferred to a country that has not been recognised by the European Commission as providing an adequate level of protection, we use an appropriate transfer mechanism, such as the European Commission’s Standard Contractual Clauses, together with supplementary safeguards where required.

Information about applicable transfer safeguards may be requested by contacting [email protected].

10. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy.

• Enquiries that do not lead to a contractual relationship are normally retained for up to 24 months after the last substantive communication.
• Records connected with an active or previous contractual relationship are retained for the duration of that relationship and for any additional period required by applicable tax, accounting, limitation and other legal obligations.
• Technical and security data is retained according to the default retention settings of our hosting and security providers, unless it is required for a longer period to investigate an incident, prevent abuse or protect legal rights.
• Data required for a legal claim, regulatory matter or investigation may be retained until that matter is resolved.

At the end of the applicable period, personal data is deleted or anonymised unless continued retention is required by law.

11. Data Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction. These measures include encrypted website delivery, access controls, service-provider safeguards, security monitoring and restricted access to business communications.

No internet transmission or storage system can be guaranteed to be completely secure. If you believe information sent to us may have been compromised, contact us promptly.

12. Your Rights

Subject to the GDPR and applicable limitations, you may have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request deletion of personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive personal data in a structured, commonly used and machine-readable format where the right to data portability applies;
• withdraw consent at any time where processing is based on consent, without affecting prior lawful processing;
• lodge a complaint with a competent supervisory authority.

To exercise a right, email [email protected]. We may request information necessary to confirm your identity and locate the relevant data. We normally respond within one month, subject to any lawful extension for complex or multiple requests.

You may lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus. Information is available at www.dataprotection.gov.cy.

13. Third-Party Links

The website may contain links to third-party websites or services. Their processing of personal data is governed by their own privacy notices. PELMENZILLA LTD is not responsible for the privacy practices or content of third-party services.

14. Children’s Data

This corporate website is intended for a general business audience and is not directed to children. We do not knowingly collect personal data from children through the website.

15. Changes to This Policy

We may update this Privacy Policy to reflect changes to the website, our processing activities or applicable law. The current version will be published on this page with an updated effective date.

16. Contact

Questions, requests and concerns about this Privacy Policy or our processing of personal data may be sent to:

PELMENZILLA LTD
Company Registration No. HE 457829
5, A.G. LEVENTI, THE LEVENTIS GALLERY TOWER, Fl.: 13th, Apt.: 1301, 1097, NICOSIA, Cyprus
Email: [email protected]