THRASSA CONSULTING LTD (“Thrassa”, “We” or the “Company”), a company incorporated and existing under the laws of the Republic of Cyprus, under registration number CY10438065Z and registered office Efesou, 9, Paralimni 5280, Famagusta, Cyprus

Thrassa is committed to protect the privacy of your information. We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information received from our website https://Thrassa.com/ (the “Website”) collected during the registration process or by telephone. This Privacy Policy may be updated from time to time for any reason, at our sole discretion. We will notify you of any material changes to our Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes. By using or accessing the Website, you confirm that you have read and understood this Privacy Policy. Please ensure you have read it carefully, and particularly the section detailing your rights in relation to the personal information that we collect about you.

If you have any questions or comments about this Privacy Policy or our use of your personally identifiable information, please contact us at support@Thrassa.com.

I. Information Сollected

Thrassa collects information from individuals who visit our Website (“Visitors”) and individuals who register to use the Services (“Customers”).

In order to access and use the Service, when you request a demo or to contact manager you are required to register for an account with us. When you register for an account, you may provide personal information to us, including first and last name, email address, job title, company name, telephone number, physical address, username and password (“Account Data”).

When purchasing the Services, Thrassa may require you to provide the Company with billing information, such as billing name and address (“Billing Information”).

As you navigate the Company’s Website, Thrassa may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Website (such as the Web pages viewed and the links clicked).

II. Use of Information Сollected

Thrassa uses Account Data to perform the Services requested or in order to take steps at your request of the prior to render the Services. For example, the Company may use information you provide to contact you on your request to further discuss your interest in the Services, to send you information about rendering of the Services or when you are requesting a demo.

Thrassa uses Website Navigational Information to operate the Company’s Website and to increase the level of protection of your account and our Website.

Thrassa may also use any of your personal information identified in this Privacy Policy for the purposes of: (i) enforcing our agreements and policies, (ii) protecting or defending our legal rights; (iv) protecting your vital interests or the vital interests of another natural person; or (v) complying with a legal obligation.

III. Your right over your information.

You have many rights over your personal information and how it is used. Here are set out the major rights, which are available to you (depending on how we collected your personal data) and how to make use of those rights:

• The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
• The right of access; this is your right to see what data we hold about you.
• The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
• The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called “the Right to be Forgotten”. This would apply if the personal data is no longer required for the purposes it was collected tor, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
• The right to restrict processing; this gives the you the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
• The right to data portability; you have the right to ask for any data supplied directly to Thrassa to be provided in a structured, commonly used, and machine-readable format.
• The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation and direct marketing.
• The right to lodge a complaint with a supervisory authority; this means that you have the right to make a complaint with the competent EU Member State authority.

IV. Special category data

Certain categories of personal information have additional protection under the GDPR. The categories include information about your health, racial or ethnic origin, etc.

We inform you, that Thrassa does not store or process such a special category of your personal data.

V. Transferring data to a third party

Thrassa may transfer your Personal information to the following third-parties categories:

• any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
• any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;
• third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;
• third parties involved by Thrassa to fulfillment of our obligations to perform Services (including hosting providers, etc.).

We may disclose Billing Information that we collect or you provide to us if you make a purchase through the Website, your credit card or debit card information is provided directly to our third-party payment processor, PayPal, to process the payments. The payment information is transmitted directly via an encrypted connection to PayPal. PayPal uses, processes and stores your personal and payment information in accordance with PayPal’s privacy policy available at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full. Thrassa does not collect or store your payment information. PayPal maintains that it is PCI compliant and you can learn more about PayPal’s security measures available at https://www.paypal.com/uk/webapps/mpp/paypal-safety-and-security.

Transferring outside of the European Economic Area

We may transfer your personal information to a third-party data processors located in countries outside of the European Economic Area ('EEA'). Thrassa only transfers your personal information to those third parties where we can be sure that we can protect your privacy and your rights, for example the third party is located in a country which the EU has deemed to have adequate data protection laws in place or to a country which has not been recognized by the European Commission as providing an adequate level of personal data protection but where we have a contract in place with that third party which includes the European Commission's standard data protection clauses.

VI. The period of storage of your information

We hold Account Data as long as it is necessary to fulfil the purpose for which it was collected. Unless otherwise legally required or agreed, Account Data, which are stored by you on our systems as part of the Service, will remain stored as long as you have an account with us, but you can delete them at any time by notifying us as it defined in section 11 under this Privacy Policy.

VII. Cookies

When you visit our Platform, we place a text file called a “cookie” in the browser directory of your computer's hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve. The cookie cannot be read by any website other than the one that set up the cookies. Some browsers can be set to reject all cookies. If you choose to modify your browser in this manner, some pages of this website may not function properly.

We also use cookies and work with third party service providers who use cookies to collect traffic data and other information about your use of our Platform. We and our service providers use this information in aggregated and anonymous form to analyze usage of our Service and to improve the operation of our Website, Services and business generally.

Our Services may include links, features or components supplied by third parties, such as the social media links, or other interactive and customizable tools. Such third parties may have information practices different than those set forth herein and their use of cookies and other technologies is not covered by this Privacy Policy. We do not have access to or control over such third parties, nor are we responsible for it or endorse it. We strongly encourage you to consult the privacy notices provided by those third parties.

VIII. Correcting and Updating your information

Customers may view, update or change their registration information by sending us a request at support@Thrassa.com. Requests to access, change, or delete your information will be handled within thirty (30) calendar days.

IX. Security

Thrassa uses appropriate administrative, technical, and physical security measures to protect Account Data against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your personal information despite our efforts. We cannot protect, nor does this Privacy Policy apply to, any information that you transmit to other users of the Website. You should never transmit personal or identifying information to other users.

X. Contacting Us

Questions regarding this Privacy Policy or the information practices of the Website should be directed to support@Thrassa.com or by mailing Efesou, 9, Paralimni 5280, Famagusta, Cyprus.