1. Controller
Gabrion Strategy Ltd
Christian Becker 

Evangelou Floraki 2, Oasis Residences, OASIS 2 Villa
8220 Chloraka / Paphos / Cyrpus

Info@gabrion-strategy.ltd

+35797434134

2. Data We Collect
- Information you provide directly: name, email, phone, company details.
- Automatically collected: IP address, browser type, cookies, and server logs.
3. Purpose and Legal Basis
We process personal data only when a legal basis under GDPR applies:
Purpose
Legal Basis
Responding to enquiries / providing services
Art. 6(1)(b) GDPR – contractual necessity
Sending newsletters or marketing updates
Art. 6(1)(a) GDPR – consent
Ensuring website security and functionality
Art. 6(1)(f) GDPR – legitimate interest
Compliance with tax and legal obligations
Art. 6(1)(c) GDPR – legal obligation
4. Data Retention
- Enquiries: retained up to 2 years after last contact.
- Newsletter/marketing data: until consent is withdrawn.
- Contractual and legal records: up to 10 years, in line with Cyprus tax law.
- Data will be deleted when no longer necessary for the purposes stated.
5. Security Measures
We apply appropriate technical and organizational measures (TOMs):
- SSL/TLS encryption
- Restricted staff access
- Regular software updates and backups
6. Sharing of Data
We may share data with third parties under GDPR-compliant agreements:
- Hosting providers
- IT and support service providers
- External consultants where strictly necessary

If external services (e.g., email or analytics providers) are used, they are listed in our Cookie or Service Notice.
7. International Transfers
If personal data is transferred outside the EU/EEA, safeguards such as Standard Contractual Clauses (SCCs) or adequacy decisions are applied.
8. Your Rights
Under GDPR and Cyprus Law 125(I)/2018, you have the right to:
- Access your personal data
- Rectify inaccurate data
- Erase data ('right to be forgotten')
- Restrict processing
- Data portability
- Object to processing based on legitimate interests
- Withdraw consent at any time
- File a complaint with the Cyprus Data Protection Commissioner

To exercise these rights, contact us at [email address]. We will respond within one month as required by GDPR.
9. Automated Decision-Making
We do not use automated decision-making or profiling within the meaning of Article 22 GDPR.
10. Children’s Data
Our services are not directed at children under 14 years old. If processing is required, parental consent is mandatory.
11. Cookies & Tracking
We use cookies for website functionality and analytics. You can manage cookies via your browser settings. For more details, please see our Cookie Policy.
12. Updates to this Policy
This Privacy Policy may be updated from time to time. Effective date: [Insert Date]. Material changes will be communicated appropriately.
13. Supervisory Authority
Commissioner for the Protection of Personal Data
15 Kypranoros Street, 1061 Nicosia, Cyprus
Website: http://www.dataprotection.gov.cy
 
 
Cookie Policy
This Cookie Policy explains how Gabrion Strategy Ltd uses cookies and similar technologies on our website.
1. What are Cookies?
Cookies are small text files placed on your device by websites you visit. They help us make our website work efficiently, improve performance, and provide a better user experience.
2. Types of Cookies We Use
- Strictly necessary cookies: essential for the operation of the website.
- Functional cookies: remember your preferences and improve usability.
- Analytics cookies: help us understand how visitors use our site (e.g., Google Analytics).
- Marketing cookies: used only with your consent to deliver personalized content or advertising.
3. Legal Basis
- Strictly necessary cookies: Art. 6(1)(f) GDPR (legitimate interest in website operation).
- Other cookies (analytics, marketing): Art. 6(1)(a) GDPR (consent).
4. Managing Cookies
You can manage or disable cookies via your browser settings. Please note that disabling certain cookies may affect the functionality of the website.
5. Third-Party Cookies
Some cookies are placed by third-party services we use (e.g., analytics or email tools). These providers may process data outside the EU/EEA under GDPR-compliant safeguards such as Standard Contractual Clauses.
6. Consent
On your first visit, we ask for your consent for non-essential cookies via a banner. You may withdraw your consent at any time by adjusting your cookie settings.
7. Updates to this Cookie Policy
We may update this Cookie Policy occasionally. Effective date: [Insert Date].