Privacy Policy
Last updated: TODO · Effective: TODO
This Privacy Policy explains how Plenora Partners ("Plenora", "we", "us") collects, uses, and protects personal data when you visit plenorapartners.com, contact us, or engage our services. We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable local law.
1. Who we are
Plenora Partners is a payments consulting and engineering firm based in Cyprus (EU). For the purposes of the GDPR, Plenora Partners is the data controller for the personal data described in this policy.
Controller contact: hello@plenorapartners.com · TODO: registered address · TODO: data protection contact / DPO if applicable.
2. The data we collect
- Information you give us — e.g. your name, email address, company, and the contents of messages submitted through our contact form or sent to us by email.
- Booking information — if you schedule a call, details provided to our scheduling provider (TODO: name the provider, e.g. Calendly).
- Technical & usage data — collected only with your consent via analytics, this may include IP address, device/browser type, pages viewed, and referring source.
- Cookies — see section 5.
3. How and why we use your data (lawful bases)
- To respond to enquiries and provide our services — on the basis of taking steps at your request prior to a contract, or performance of a contract.
- To operate and secure the website — on the basis of our legitimate interests in running a safe, functional site.
- To improve the site through analytics — on the basis of your consent, which you can withdraw at any time.
- To meet legal obligations — where we are required to retain or disclose data by law.
4. Marketing
We do not send marketing communications without an appropriate lawful basis. Where we rely on consent, you can withdraw it at any time by contacting us. TODO: describe any newsletter (e.g. Plenora Pulse) sign-up and opt-out mechanics.
5. Cookies and analytics
We use essential cookies required to run the site, and — only after you accept via our cookie banner — optional analytics cookies that help us understand and improve usage. You can accept or reject non-essential cookies on your first visit, and change your choice at any time using Cookie preferences in the footer. Non-essential and analytics scripts are not loaded until you consent.
TODO: list the specific cookies and analytics provider(s) used (name, purpose, retention).
6. Sharing your data
We do not sell your personal data. We share it only with service providers acting on our behalf (data processors) under appropriate agreements — for example website hosting, scheduling, and analytics — and where required by law. TODO: list processors.
7. International transfers
Where personal data is transferred outside the EEA, we rely on appropriate safeguards such as adequacy decisions or Standard Contractual Clauses. TODO: confirm which transfers apply and the safeguards in place.
8. Retention
We keep personal data only for as long as necessary for the purposes described above, after which it is deleted or anonymised. TODO: specify retention periods (e.g. enquiry data retained for X months; client records per contractual/legal requirements).
9. Your rights under the GDPR
Subject to applicable law, you have the right to:
- access the personal data we hold about you;
- request correction of inaccurate or incomplete data;
- request erasure of your data ("right to be forgotten");
- restrict or object to certain processing;
- data portability;
- withdraw consent at any time, without affecting prior lawful processing;
- lodge a complaint with a supervisory authority — in Cyprus, the Office of the Commissioner for Personal Data Protection (TODO: confirm authority and link).
To exercise any of these rights, contact hello@plenorapartners.com. We will respond within the timeframes required by law.
10. Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. No method of transmission or storage is completely secure, but we work to protect your data and review our measures regularly.
11. Changes to this policy
We may update this policy from time to time. Material changes will be reflected by updating the "Last updated" date above and, where appropriate, by notice on the site.
12. Contact us
Questions about this policy or your data? Email hello@plenorapartners.com or use our contact page.