Privacy & Data Protection Policy
(Effective date: 01.05.2024, Version: 1.0.1)
1. Introduction
This Privacy & Data Protection Policy explains how Bullconcept Smart Solutions Ltd. (“Bullconcept”, “we”, “our” or “us”) collects, uses, stores and protects your personal data when you visit our website https://bullconcept.com, interact with us online or offline, or use our services.
We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the relevant national legislation in Cyprus.
If you have any questions, you can contact us at:
- Data Controller: Bullconcept Smart Solutions Ltd.
- Registered office: 26, A. Mavrokordatou Str., CY-3116 Agia Fyla, Limassol – Cyprus.
- Email for privacy matters: privacy@bullconcept.com
- Telephone: +357 25 250222
- Data Protection Officer (DPO): Mr. Michael P. Tanczos
2. Definitions
For the purposes of this Policy:
- “Personal Data” means any information relating to an identified or identifiable natural person.
- “Processing” means any operation performed on personal data (collection, storage, use, disclosure, etc.).
- “Controller” means the person or entity that determines the purposes and means of the processing.
- “Processor” means a person or entity processing personal data on behalf of the controller.
3. Categories of Personal Data We Process
We collect and process the following categories of personal data:
| Category | Examples | Source |
| Identification & Contact | Full name, postal address, email, phone number | Provided by you via forms, email, phone |
| Customer Relationship | Billing information, order history, payment data (excluding full card numbers) | Provided by you / generated during service |
| Technical / Usage Data | IP address, browser type, device identifiers, log files, cookie IDs | Automatically collected when using our website |
| Communications | Messages sent via contact forms, email correspondence, support tickets | Provided by you |
| Marketing Preferences | Newsletter subscriptions, opt-in/opt-out choices | Provided by you |
We do not knowingly collect data of children under the age of 18 without parental consent.
4. Purposes of Processing & Legal Bases
We will only process personal data where we have a lawful basis under GDPR. The main purposes and legal bases are:
| Purpose | Legal basis under GDPR |
| To respond to enquiries and provide quotations | Contract (Art. 6 (1)(b)) or pre-contractual steps |
| To provide and deliver ordered products or services | Contract (Art. 6 (1)(b)) |
| To manage invoicing, accounting, and legal obligations | Legal obligation (Art. 6 (1)(c)) |
| To communicate service updates or important notices | Legitimate interest (Art. 6 (1)(f)) or legal obligation |
| To send marketing emails or newsletters | Consent (Art. 6 (1)(a)) – you may withdraw at any time |
| To maintain website security and prevent fraud | Legitimate interest (Art. 6 (1)(f)) |
| To comply with lawful requests by authorities | Legal obligation (Art. 6 (1)(c)) |
Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
5. Cookies & Tracking Technologies
We use cookies and similar technologies on our website. For full details see our Cookie Policy.
We will not set non-essential cookies (analytics, marketing) without your prior consent via our cookie banner.
| Category | Purpose | Examples | Retention |
| Strictly necessary | Essential for site operation | Session cookie | Session |
| Preferences | Store language or site preferences | Language cookie | Session |
| Analytics | Understand site traffic | Google Analytics | Session |
| Marketing | Track ads and remarketing | Facebook Pixel | Session |
You can change or withdraw your cookie consent at any time via the banner or your browser settings.
6. Disclosure to Third Parties & International Transfers
We will only share your data with trusted service providers (“processors”) under written agreements that require them to handle your data securely and only under our instructions.
Typical recipients include:
- IT hosting & support providers
- Payment service providers
- Accounting / bookkeeping partners
- Delivery and courier services
- Email marketing platform (if subscribed)
- Hard / Software Manufacturers (e.g., warranty / licensing purposes)
If we transfer personal data to countries outside the European Economic Area (EEA), we will ensure appropriate safeguards, such as:
- Adequacy decisions by the European Commission
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Binding Corporate Rules (BCRs)
7. Retention of Data
We retain personal data only as long as necessary for the purposes described, and as required by applicable law (e.g., tax/accounting).
| Data type | Typical retention period |
| Customer account and order records | 7 years after end of contract to meet tax law |
| Enquiries and correspondence | 12 months after last contact |
| Marketing list (email) | Until you unsubscribe or withdraw consent |
| Technical logs | 12 months |
| CCTV footage (if any) | 30 days |
When retention periods expire, we securely delete or anonymize data.
8. Your Rights
Under GDPR you have the following rights (subject to legal limits):
- Right of access to your data
- Right to rectification of inaccurate data
- Right to erasure (“right to be forgotten”)
- Right to restrict processing
- Right to object to processing (including direct marketing or were based on legitimate interest)
- Right to data portability (for data provided by you and processed by automated means)
- Right to withdraw consent at any time
- Right to lodge a complaint with the supervisory authority:
Office of the Commissioner for Personal Data Protection, Cyprus
Website: https://www.dataprotection.gov.cy
Tel: +357 22 818 456
To exercise your rights, contact us at privacy@bullconcept.com.
9. Security of Your Data
We implement appropriate technical and organizational measures to protect personal data, including:
- Encryption in transit and at rest where feasible
- Access control and authentication for staff
- Regular backups and secure storage
- Staff confidentiality and data protection training
10. Automated Decision-Making & Profiling
We do not use personal data for automated decision-making that produces legal or similarly significant effects on you.
11. Children
Our services are not directed at individuals under the age of 18 and we do not knowingly collect data from them. If we learn that we have collected data of a child without appropriate consent, we will delete it promptly.
12. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for their privacy practices. We encourage you to review their privacy policies.
13. Changes to This Policy
We may update this Policy from time to time to reflect changes in law or our practices.
We will indicate the effective date and, where significant changes are made, we will notify you via our website or by email if appropriate.
14. Contact
For any questions or to exercise your rights under this Policy, please contact:
- Bullconcept Smart Solutions Ltd.
- Email: privacy@bullconcept.com
- Address: 26, A. Mavrokordatou Str., CY-3116 Agia Fyla, Limassol – Cyprus.
- Phone: +357 25 250 222