The Foreword

In line with Regulation (EU) 2016/679 (hereinafter the “GDPR”) , we collect your personal data only to the extent necessary to perform our business needs and, in some cases, comply with applicable law. Here you can find information on how we process your personal data.

This Privacy Policy (hereinafter the “Policy”) applies to:

• The Website https://lambrie-software.com/ (hereinafter the “Website”);

• Our e-mail addresses.

Legal information about a data controller

The Website is owned, administered, and operated by Lambrie Investments Limited, the company incorporated in the Republic of Cyprus, with its registered address at Kasou, 13, Strovolos, 2062, Nicosia, Cyprus, with its registration number ΗE 332545 (hereinafter the “Company”, “we”, “us”, “our”).

Within the meaning of Article 4(1)(7) of the GDPR, the Company is a data controller, that determines the purposes and means of the processing of personal data of the Website Users.

You can contact us for any issue, including this Policy, via the following e-mail address info@lambrie-software.com.

What personal data do we collect?

Technical information. When You access and use our Website we automatically receive collected information via technical facilities of the Website and via Google and Cloudflare services, and from cookies (see Cookie Notice). This information includes the following:

• Your IP address;

• Your user-agent string: a browser’s user agent string (UA) which helps to identify a browser is being used, what version, and on which operating system;

• The information concerning your use of the Website: the web-pages you’ve clicked on, which pages were visited by you, in what order, the information about the source from which you’ve got into the Website.

Contact information. When you communicate with us via the Website or our e-mail, you provide us with the following information:

• Your e-mail address;

• Your name;

• Your phone number (optional).

Communication records. We collect the content of your communications with us.

Research information. If You represent an organisation interested in our services, we may do analytical research of the information about this organisation and Your from open sources on the Internet. This information may include:

• Organisation name, country of registration, location, size, structure, etc.;

• Industry, the sphere of activity, etc.;

• Information about You, posted by You on the pages of social networks, as well as available by search on the Internet, in particular, regarding Your position, work experience, career, etc.

For what purposes, on what legal bases do we use your personal information?

Here you can find out for what purposes we process your personal information. Additionally, we’ve specified the legal basis for each processing purpose. If you want to know more about legal bases, please read Article 6 of the GDPR.

Provide you with the Website. We use your technical information to provide you with the Website. Without technical information, the Website will either not work our will work with mistakes. We use legitimate interest to provide Users with our Website as the legal basis (Article 6 (1)(f) of the GDPR).

Protect the Website. We use your technical information to protect the Website from cyberattacks, abuse, and fraudulent activity. We use legitimate interest to protect the Website as a legal basis (Article 6 (1)(f) of the GDPR).

Develop and enhance the Website and our services. We use your technical information, your communication records, anonymize them and use this information to understand how Users interact with our Website. We use legitimate interest to develop and enhance our Website and our services as a legal basis (Article 6 (1)(f) of the GDPR).

Test new features of the Website. We use your technical information to test new Website interfaces, for example, for so-called A/B tests. We use legitimate interest for testing new features and products on the Website (Article 6 (1)(f) of the GDPR).

To contact you. We use your contact information and communication records to contact you when required by the situation. If you implement your data subject right or we communicate with you in the context of other legal matters, we use legal obligation as a legal basis (Article 6 (1)(c) of the GDPR). If you send us a general enquiry relating to the Company or its product or services, the legitimate interest is used for communication (Article 6 (1)(f) of the GDPR).

To establish business relationships. If you are a representative of an organisation, we will use your contact information, research information, and communication history to enter into pre-contractual negotiation with your organisation. In this case, the legitimate interest to conduct business relationships with other companies is used (Article 6 (1)(f) of the GDPR).

How long your personal information will be stored?

The technical information will be stored up to 26 months. Please follow this link to Google’s website in order to find out more.

Contact information, research information, communication history will be stored for a period necessary for the purposes described above. When the purpose is reached, the data will be erased. If we have negotiated to enter into a contract with your organisation, further processing of your personal information will be governed by another privacy policy which will be delivered to you before the signature of a contract.

Recipients of your data and international data transfer

In this clause you can find the list of recipients of your personal data. Additionally, in accordance with the data protection law, we are under a legal obligation to notify you about the transfer of your personal information to a third country or an international organisation. The “third country” means the country another to EEA state. In order to find out more about EEA, please follow this link.

Additionally, we are obliged to describe you the legal mechanisms which are used for these transfers. Generally, we use so-called Standard Contractual Clauses. The clauses are approved by the European Commission and oblige the recipient of the personal information in a third country or international organisation to process this information in accordance with the legislation in force in the country of an exporter of personal information (in our case, the Republic of Cyprus). To find out more, please follow this link.

Transfer of your data within our business group. Our business is maintained and supported by other legal entities; for example, some facilities of the company are provided by our independent contractors, external auditors. Thus, your personal data may be disclosed to them. In case of the transfer to the third country or international organisation, we will use Standard Contractual Clauses.

Third-party auditors, contractors, suppliers. In some cases, we may engage third parties for the processing of your personal information. Examples include, without limitation: i) you are interested in business relationships with the Company, but your situation requires external resources; ii) in case of any bad faith conduct, attacks on the Website or our technical infrastructure when this situation requires engagement of additional external resources; iii) our Company passes independent audit, and external auditor receives and access to your personal information. In case of the transfer to the third country or international organisation, we will use Standard Contractual Clauses.

Hosting provider which makes the Website available. Our Website is placed on a third-party server, which means that your personal information will be placed on this server. Please note that information is stored in encrypted form, which makes impossible to decrypt your personal information without decryption keys which are in sole possession of the Company.

Google and Cloudflare. We deploy the services provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Dublin, 368047, Ireland, Google LLC, Amphitheatre Parkway, Mountain View, CA 94043, USA and Cloudflare, Inc.,101 Townsend St, San Francisco, CA 94107 USA. Please read more in Google Privacy Policy and Cloudflare Privacy Policy.

Please note that Google and Cloudflare transfer data from the EU to the United States. These transfers are secured by Standard Contractual Clauses.

Your rights

As the data subject, you have several rights which you can implement either by contacting us via email info@lambrie-software.com or by sending a request to our legal address.

You have the right to access, correct, or delete your personal information and the right to restrict its processing or object against such processing. You also have the right to data portability.

If you suppose that your rights under applicable data protection legislation have been violated, you can lodge a complaint either:

• With the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus. The Website of the Commissioner http://www.dataprotection.gov.cy/; or

• With the data protection authority of the country or land of your work or residence. You can find the list of all EU`s Data Protection Authorities on the Website of the European Data Protection Board https://edpb.europa.eu/about-edpb/board/members_en.

Changes

We reserve the right, from time to time, to change, amend, modify, or correct this Policy. In any case, we will post the updated Policy on the Website. Be careful and monitor any updates of this Policy.

Effective Date: 12 April 2021