Privacy Policy
1. Who we are
This privacy policy applies to the website friedotech.com(the “Site”) operated by:
FRIEDOTECHNOLOGY LTD
Evripidou 31, NBA Seapark Court
Flat / Office 102
Limassol 3031, Cyprus
Email: info@friedotech.com
In this policy, “we”, “us”, or “our” refers to FRIEDOTECHNOLOGY LTD. We are the data controller for any personal data collected through this Site, as defined under Regulation (EU) 2016/679 (the General Data Protection Regulation, or “GDPR”) and the Cyprus Law 125(I)/2018 on the Protection of Natural Persons with regard to the Processing of Personal Data.
2. Scope of this policy
This policy explains how we collect, use, store, and protect personal data when you visit friedotech.com or contact us via the channels listed on this Site. It does not apply to any product websites we operate (such as lead-optima.com), which have their own privacy policies.
If you contact us about our products, we may direct you to the relevant product’s privacy policy for product-specific data processing.
3. What personal data we collect
We aim to keep data collection on this Site to a minimum.
3.1 Information you provide directly
If you contact us by email (info@friedotech.com), we receive:
- Your email address
- Any name, organisation, or other information you choose to include in your message
- The contents of your message itself
3.2 Information collected automatically
When you visit the Site, our hosting provider may automatically log technical information for security, performance, and abuse-prevention purposes. This may include:
- Your IP address
- Browser type and version
- Operating system
- Pages visited and timestamps
- Referring URL
We do not use behavioural tracking cookies, third-party advertising cookies, or analytics that profile individual visitors on this Site.
3.3 Cookies
This Site uses only strictly necessary technical cookies required for the Site to function (for example, session identifiers if applicable). No marketing, advertising, or analytics cookies are set.
If we add optional cookies in the future, we will request your consent in advance in accordance with Article 5(3) of the ePrivacy Directive as implemented in Cyprus by Law 112(I)/2004.
4. Legal basis for processing
We process personal data on the following legal bases under Article 6 of the GDPR:
- Legitimate interests (Article 6(1)(f)) — to respond to your inquiries, maintain Site security, and prevent abuse
- Consent (Article 6(1)(a)) — where we explicitly ask for it (for example, future optional cookies or newsletter sign-ups)
- Legal obligation (Article 6(1)(c)) — where required by Cyprus or EU law, such as anti-money-laundering record-keeping or response to lawful authority requests
5. How we use your data
We use the personal data we collect to:
- Respond to inquiries you send us
- Maintain and secure the Site
- Comply with our legal and regulatory obligations
- Defend our legal interests where necessary
We do not sell, rent, or trade personal data. We do not use personal data for automated decision-making or profiling within the meaning of Article 22 of the GDPR.
6. Sharing your data
We share personal data only with:
- Service providers acting as data processors on our behalf, including our hosting provider and email infrastructure provider, bound by data processing agreements that comply with Article 28 of the GDPR
- Group companies and product subsidiaries where strictly necessary (for example, forwarding a product-specific inquiry to the relevant team)
- Legal and regulatory authorities where we are legally required to do so, including Cyprus regulators, EU authorities, and courts
We do not transfer personal data to commercial third parties for their own purposes.
7. International transfers
Where personal data is transferred outside the European Economic Area, we ensure such transfers are protected by appropriate safeguards under Chapter V of the GDPR, including Standard Contractual Clauses adopted by the European Commission, or transfers to countries with an adequacy decision.
8. How long we keep your data
We retain personal data only for as long as necessary for the purposes for which it was collected:
- Email correspondence: retained for up to 24 months after the last interaction, unless an ongoing business relationship requires longer retention
- Server access logs: retained for up to 12 months for security and abuse-prevention purposes
- Records required by law: retained for the period required under applicable Cyprus or EU law (for example, tax and accounting records under the relevant Cyprus statutes)
After these periods, data is securely deleted or anonymised.
9. How we protect your data
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction, including:
- Encryption of data in transit (TLS/HTTPS)
- Access controls on systems holding personal data
- Regular security review of our hosting and infrastructure
- Internal data-handling policies for staff and contractors
No system is perfectly secure. In the event of a personal data breach affecting your rights and freedoms, we will notify the Cyprus Commissioner for Personal Data Protection within 72 hours where required, and you directly where appropriate, in accordance with Articles 33 and 34 of the GDPR.
10. Your rights
Under the GDPR and Cyprus Law 125(I)/2018, you have the right to:
- Access — request a copy of the personal data we hold about you (Article 15)
- Rectification — request correction of inaccurate or incomplete data (Article 16)
- Erasure — request deletion of your data where the conditions in Article 17 are met
- Restriction — request that we limit how we process your data (Article 18)
- Portability — request your data in a structured, commonly used, machine-readable format (Article 20)
- Objection — object to our processing of your data based on legitimate interests (Article 21)
- Withdraw consent — at any time where we rely on your consent, without affecting prior processing
- Lodge a complaint — with a supervisory authority, including the Cyprus Commissioner for Personal Data Protection (see Section 12)
To exercise any of these rights, contact us at info@friedotech.com. We will respond within one month, as required under Article 12(3) of the GDPR. We may need to verify your identity before processing your request.
11. Children’s data
This Site is not directed at children. We do not knowingly collect personal data from individuals under 14 years of age (the age of digital consent under Cyprus Law 125(I)/2018 Article 8). If you believe a child has provided us with personal data, contact us and we will delete it.
12. Supervisory authority
You have the right to lodge a complaint with the Cyprus data protection authority:
Office of the Commissioner for Personal Data Protection
1 Iasonos Street, 2nd Floor
1082 Nicosia, Cyprus
Email: commissioner@dataprotection.gov.cy
Website: www.dataprotection.gov.cy
13. Changes to this policy
We may update this policy from time to time. The “Last updated” date at the top of this page reflects the most recent revision. Material changes will be communicated through a prominent notice on this Site or, where appropriate, by direct contact.
14. Contact
For any questions about this policy or how we handle personal data:
FRIEDOTECHNOLOGY LTD
Evripidou 31, NBA Seapark Court, Flat / Office 102
Limassol 3031, Cyprus
Email: info@friedotech.com