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Privacy Policy
Last updated: 28 February 2026 · Effective date: 28 February 2026
This Privacy Policy describes how ______ Ltd. ("we", "our", "the Company") collects, uses, stores and protects personal data when you interact with the Funny Sunny Cyprus website at funny-sunny.abs.cy.
We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation — "GDPR"), the Law on the Protection of Personal Data of Cyprus (N. 125(I)/2018), and other applicable European Union and Republic of Cyprus legislation.
1. Data We Collect
We may collect the following categories of personal data:
- Contact information: full name, email address, telephone number — provided voluntarily when you contact us by email or phone.
- Business information: company name, position/role, website — provided voluntarily in the context of a business enquiry.
- Communication data: content of messages, emails and correspondence you send to us.
- Technical data: IP address, browser type, operating system, pages visited — collected automatically via server logs and standard web server functionality. We do not use tracking cookies or analytics platforms.
2. Purposes and Legal Bases for Processing
We process personal data for the following purposes and on the following legal bases under Article 6 GDPR:
- Responding to business enquiries (Art. 6(1)(f) GDPR — legitimate interest): When you contact us regarding a distribution partnership or product samples, we process your contact data to respond and evaluate cooperation.
- Pre-contractual and contractual measures (Art. 6(1)(b) GDPR): If discussions progress to a distribution agreement, we process data necessary to prepare and execute the contract.
- Legal obligations (Art. 6(1)(c) GDPR): We retain certain records as required by Cyprus and EU tax and commercial law.
- Consent (Art. 6(1)(a) GDPR): For any processing not covered above, we will request your explicit consent.
3. How We Use Your Data
- To respond to your enquiries and provide information about Funny Sunny products and partnership terms.
- To arrange delivery of product samples upon your request.
- To prepare, negotiate and execute distribution agreements.
- To maintain records of business communications as required by applicable law.
- To ensure the security and integrity of our website and communications.
We do not use your personal data for automated decision-making or profiling. We do not sell, rent or share your personal data with third parties for marketing purposes.
4. Data Retention
We retain personal data only for as long as necessary for the purposes described above:
- Business enquiries (no contract concluded): up to 2 years from the date of last contact.
- Pre-contractual and contractual correspondence: for the duration of the contract and up to 5 years thereafter, as required by applicable accounting and commercial law.
- Technical logs: up to 90 days, for security and maintenance purposes.
After the retention period expires, data is securely deleted or anonymised.
5. Data Sharing and Transfers
We do not transfer your personal data to third parties, except:
- Service providers acting as data processors on our behalf (e.g. email hosting, web hosting) — bound by data processing agreements ensuring GDPR compliance.
- Legal authorities — only when required by law or a court order.
All data processing takes place within the European Economic Area (EEA). No transfers to third countries outside the EEA are made. If this changes in the future, we will ensure appropriate safeguards (such as Standard Contractual Clauses) are in place.
6. Your Rights Under GDPR
As a data subject under GDPR, you have the following rights:
- Right of access (Art. 15): You may request a copy of the personal data we hold about you.
- Right to rectification (Art. 16): You may request correction of inaccurate or incomplete data.
- Right to erasure ("right to be forgotten") (Art. 17): You may request deletion of your personal data, subject to legal retention obligations.
- Right to restriction of processing (Art. 18): You may request that we restrict the processing of your data in certain circumstances.
- Right to data portability (Art. 20): You may request your data in a structured, machine-readable format.
- Right to object (Art. 21): You may object to processing based on legitimate interests.
- Right to withdraw consent (Art. 7(3)): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at a.belov@abs.cy. We will respond within 30 days in accordance with Article 12 GDPR.
7. Cookies and Tracking Technologies
This website does not use cookies for tracking, analytics or advertising. Standard web server logs (IP addresses, page requests, timestamps) are processed for security and operational purposes and are deleted after 90 days.
If you have linked to this site from a third-party platform (e.g. Google), that platform's own cookie and privacy policies apply to their services, which are outside our control.
8. Website Links
Our website may contain links to third-party websites (e.g. distributor websites). We are not responsible for the privacy practices or content of those websites. We encourage you to review their privacy policies before providing any personal data.
9. Data Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or alteration, including the use of encrypted communication channels (HTTPS), restricted access to data, and secure email practices.
10. Supervisory Authority
If you believe we have processed your personal data unlawfully or failed to respect your rights, you have the right to lodge a complaint with the supervisory authority:
You may also lodge a complaint with the supervisory authority in any EU Member State where you reside or work, or where the alleged infringement occurred.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be published on this page with a revised "Last updated" date. We encourage you to review this policy periodically.
12. Contact
For any questions, requests or concerns regarding this Privacy Policy or our data processing practices, please contact us: