Privacy Policy

Privacy notice

At NULLKER we understand that your privacy is important to you and that you care about how your personal data is used.  We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the applicable local legislation, the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the- EU Regulation No. 2016/679 the General Data Protection Regulation (collectively “GDPR”). This Privacy Notice sets out the basis on which we may collect, use or otherwise process personal data via our website (Website), downloadable software, content, features, function and/or via the User Profile and/or via any other services provided by us and on which a link to this Privacy Notice is displayed, and/or all other communication with you through written or oral means, such as email, chat or phone when you use our Services (as defined in the Terms and Conditions) and the choices you have associated with that personal data.  

Please note that this Privacy Notice is addressed to Users, Project Owners and Partners (as these are defined in the Terms and Condition). If you are, were or may be an employee or third party contractor your personal information will be used in connection with your agreement in accordance with a separate privacy policy.

We use your personal data to provide and improve our Services.  Your acceptance of this Privacy
Notice is deemed to occur upon your first use of our Website.

1. Introduction

NULLKER is a business name owned and operated by NT FORCE LTD, a limited liability company incorporated and registered in the Republic of Cyprus under company number ΗΕ424537 and have its registered office address Kolonakiou 42, Agios Athanasios 4103, Limassol, Cyprus and is the Controller and responsible for the personal information you disclose to us to make use of our Services through the Website.

This Privacy Notice is issued on behalf of NULLKER. NULLKER is active across the world. We have offices located in Cyprus, together with their respective related and affiliated entities, (collectively referred to as “NULLKER  ”) so when we mention “NULLKER”, “Company”, “we” or “us” in this Privacy Notice we are referring to the relevant company responsible for collecting and/or processing your personal data when you use the Services. NULLKER  respects your privacy and is committed to protect your data, which it collects and/or has access to.

We take measures to implement advanced data protection policies and procedures and to update them from time to time for the purpose of safeguarding the users’ of our Website data. Your data is protected by the legal, administrative and technical measures that we take to ensure the privacy, integrity and accessibility of data. To prevent security incidents with your data, we use a mixed organizational and technical approach based on the results of our annual risk assessment.

We shall not divulge any private information unless you approve in writing such disclosure or unless such disclosure is required under applicable law or is required in order to verify the User's identity, or it is required for us to perform our contractual obligations under any agreement concluded with us. The personal data is processed only by our employees and/or trusted third parties which provide specific services, necessary for the provision of our Services. All such information shall be stored on electronic and physical storage media according to applicable law.

2. Data collections

We collect, process, store and transfer different kinds of personal data about you for various purposes in order to be able to provide and improve our Service to you.  Depending upon your use of the Service we may collect some or all the  personal data set out below as follows: 

  • Identity Data includes first name, last name, date of birth, gender, passport/ID, Driver’s number, and copy of photo.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and other technologies on the devices you use to access the Website and use of cookies stored on your device.
  • Profile Data includes your User profile details, username and password, transactions made by you, your interests, preferences, feedback and/or information received through your interaction with us within the course of providing our Services and survey responses.
  • Usage Data includes information about how you use Website, products and Services and IP history.
  • Data in KYC (Know your customer) includes identity document information, including copies of recent dated Utility Bills, Identity Card, Passport, and/or Driver’s License, Tax Identification Numbers (TIN).
  • Location Data includes details on your actual location when interacting with our Website (for example, a set of parameters that determine regional settings of your interface, namely residency country, time zone, and the interface language).
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Audio Data includes full voice recordings of calls that you receive from us or make to us.
  • Aggregated Data includes statistical or demographic data for any purpose. Such data can be derived from your data but may not be considered personal data in law as it will not directly or indirectly reveal your identity. An example of such Aggregated Data could be that we aggregate your Usage Data to calculate the percentage of users accessing a specific website feature and/or services/product preference. Notwithstanding the above, if the Company combines Aggregate Data with data in a way that the end result can in any way identify the data subject, the Company shall treat such combined data as data which will be treated as per the provisions herein contained.

(the above collectively referred to as “personal data”)

Our Website is not intended for children and we do not knowingly collect data relating to children. As we do not allow users under the age of 18 to use our services, we need to obtain your birth date in order to confirm the Clients’ age checks.

3. Processing of your data

Processing of your personal data is carried out by NULLKER following the principles of lawfulness, fairness, transparency and always adhering to the intended purpose of data processing, the principle of data minimization, accuracy, limited data storage, data integrity, confidentiality and accountability. NULLKER  may process your personal data for any of the following reasons:

  • To perform its Agreement with you,
  • To publish details of your Projects, Pledges or Rewards (as the case may be),
  • To set up recurring Pledges,
  • To share your personal data with trusted Partners, Project Owners and/or Users (as the case may be),
  • To perform compliance checks, such as verification of your identity, and helping to detect fraudulent or malicious activity on our Website, Platform or Services,
  • To maintain our accounts and records,
  • To manage our business needs, such as monitoring, analysing, and improving the Services and the Website’s performance and functionality,
  • To comply with all applicable laws and regulations; and/or
  • For the purposes of safeguarding our legitimate interests and your interests and fundamental rights do not override those interests.

Legitimate interests. We may use and process your personal data where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

  1. Processing necessary for us to promote our business, brand and activities and measure the reach and effectiveness of our campaigns:
  • for analysis and insight conducted to inform our marketing strategies, and to enhance and your visitor experience;
  • to tailor and personalise our marketing communications based on your attributes;
  • to supply your details to social media and other online platforms operated by other companies for them to contact you with our targeted advertising online, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please see further ‘Our use of social media’;
  • to identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information);
  • to send you emails about your projects or your Subscription;
  • to supply your details to a Project Owner where you have made a Subscription to
  1. Processing necessary for us to respond to changing market conditions and the needs of our guests and visitors:
  • to analyse, evaluate and improve our Website and other services so that your visit and use of our Website and social media pages, are more useful and enjoyable (we will generally use data amalgamated from many people so that it does not identify you personally);
  • to undertake market analysis and research (including contacting you with surveys) so that we can better understand you as a guest;
  • for the purposes of developing new initiatives and features on our Website (for example new types of fundraising options or support.
  1. Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
  • to administer our Website and our social media pages and for internal operations, including troubleshooting, testing, statistical purposes;
  • to evaluate whether your Project should receive funding from our Users, including by sharing your personal information with the relevant User(s);
  • for the prevention or detection of fraud and other criminal activities or to assist in the apprehension of offenders, including by sharing your personal data with the relevant partner(s);
  • to verify the accuracy of data that we hold about you and create a better understanding of you as an account holder or visitor;
  • for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access, including to archive, destroy, pseudonymise or anonymise your personal information;
  • to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
  • for the purposes of corporate restructure or reorganisation or sale of our business or assets;
  • for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
  • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
  • to inform you of updates to our terms and conditions and policies; and
  • for other general administration including managing your queries, complaints, or claims, and to send service messages to you.

Marketing. We process your personal data to send direct marketing of our Services to you, always within the boundaries of our legitimate interests. For example we might use your personal data to send to you newsletters, push-messages and calls to keep you in touch with our new features and new development of the current products/services we offer, news and events and the efficient provision of the full scope of our Services. We will also use your data to send you marketing information regarding our services that we believe may be of interest to you via email or otherwise. This processing is necessary for our legitimate interests (to provide effective and personalized customer services to you and to update you in relation to our Services that are available to you. If you dont want to receive any marketing newsletters or transmit your data to third-parties for marketing purposes, nor to receive notifications for updates, you can contact us using the CONTACT DETAILS BELOW.

4. Data retention

We will not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected in accordance with this Privacy Notice. To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting and other requirements.

To comply with the applicable legal, regulatory, tax, accounting requirements we keep your personal data for a minimum period of 5 years from the date our business relationship is terminated. We may need to retain your information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate business purposes, such as to respond to queries or complaints, fighting fraud and financial crime and responding to requests from regulators.

At the expiration of the personal data retention period the personal data is erased by irreversible destruction and we also inform all third parties, to whom the personal data was transferred, regarding such erasure and request implementation of similar actions on their part.

5. Data security

We protect your data by adhering to industry standard regulations on data protection by categorising them into data types (e.g. technical, personal data, cookie data, etc) while applying relevant protection processes and due diligence procedures. Therefore, we apply appropriate technical and organisational controls to protect your data, including secure computer systems adopting least privilege access in order to prevent unauthorised access, disclosure, modification, or destruction of personal data. Any hard copy documents are locked in a secure cabinet, and destroyed once no longer required.

For providing more trust and security we use SSL Certificates. You can see this in the supported browser versions which confirms what all transmitted personal data is secure.

Protection of your personal data in our infrastructure. We make it a priority to develop Services that are secure "by default". The "default" security of our Services means that every new services and features are designed with strict security requirements in mind before we even begin development. This is the key to guaranteed protection and privacy of all personal data that our Services handle and store, once the service or new feature is released.

NULLKER is always vigilant about the Security of the personal data stored in our infrastructure. Because of that we locate all our equipment used for your personal data processing in secure personal data centres. Network access to this equipment is isolated from the Internet. We use network segmentation for isolation of Services which need different level of security from each other. In addition, we restrict logical access to the personal data for our employees on "need to know" basis. So, only personnel, who really require access to the personal data for the purpose of providing you with our best Service, will have access to it.

Threats protection. NULLKER is highly knowledgeable about modern threats to personal data security and privacy, and we are well prepared to combat them. All events that occur in our infrastructure are continuously monitored, analysed and responded, which allows us to ensure proper protection of your personal data, keeping it safe from threats, vulnerabilities, and the effects of malware.

In the event of a failure that affects the accessibility of your personal data, we have personal data backup and recovery procedures in place that will us help to restore your personal data in short time. For further guarantee the quick recovery we use high availability mode enabled for most critical databases which allows us to minimize downtime.

Employee awareness of data security. 

Our employees may handle your personal data in order to provide you with the first-class Service. To guarantee the security and confidentiality of your personal data, we monitor all employees’ actions with access to your personal data in our systems and grant access strictly on a "need to know" basis: only employees who need access will receive it. We hold regular training sessions to make sure that each employee understands the principles that NULLKER  follows to achieve robust data security and privacy.

If you choose not to give your personal information.

In the context of our business relationship we may need to collect data by law, or under the terms of a contract we have with you. Without this data, we are, in principle, not in a position to close or execute a contract with you. If you choose not to give us this data, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform the Services.

To what extent we carry automated decision-making and profiling. In establishing and carrying out a business relationship, we generally do not use automated decision-making. If we use this procedure in individual cases, we will inform you of this separately. In some cases, we may proceed with profiling in order to evaluate certain personal aspects. We shall inform you accordingly in case we perform any profiling. In general, any data collection that is optional would be made clear at the point of collection.

6. Data collections

We use different methods to collect data from and about you including through:

Direct Interactions. You will provide to us your personal data online through the Website and/or by completing and filling online forms and/or by corresponding with us by emails or otherwise. Personal data is submitted to us when you register an Account with us.

We require to collect the above data in order to that we are able to (i) provide our Services efficiently, (ii) to comply with our ongoing legal and regulatory obligations, including, inter alia, (a) to prevent fraud and money laundering acts and/or (b) conduct the assessment of suitability and appropriateness test.

If you fail to provide the data when requested we may not be able to perform the contract we have or trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.

Automated Technologies or Interactions. When using our services, your device automatically transmits to us its technical characteristics. Locale (a set of parameters that determine regional settings of your interface, namely, residence country, time zone and the interface language) is used for the purpose of providing you with the best possible service within our platform.

Using the information about IP address, cookies files, information about browser and operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile and/or desktop versions of our application and monitor your behaviour for the purpose of improving the efficiency and usability of our Services.

We use web analytics tools to track performance of our website and marketing source of user by cookies in order to optimize our marketing costs and provide users with better experience.

You may at any time request that we refrain from any such transmissions (to the degree this is possible and subject to any of our legal obligations) by sending your request to the DPO using our details in the OUR CONTACT DETAILS below using the registered email address you disclosed and registered with us. We will address your request within 30 business days.

7. Cookies

A cookie is a small amount of data that often includes a unique identifier that is sent to your computer or device browser from a website's computer and is stored on your device's hard drive for tracking site usage. A website may send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. First-party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our Website and to provide and improve our products and Services.  We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is always protected and respected.

By using our Website, you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services, and/or parties other than us. For more details, please refer to the table below.  All Cookies used by and on our Website are used in accordance with applicable legislation on the use of cookies

Our Website uses analytics services, which are a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our Website is used. This, in turn, enables us to improve our Website and the Services offered through it. You do not have to allow us to use these cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Website, it does enable us to continually improve our Website, making it a better and more useful experience for you.

You will be required to provide cookie consent by acknowledging the privacy and cookie policies during registration of your account. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended.

You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our Website more quickly and efficiently including, but not limited to, login and personalisation settings.  It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

You can instruct your browser to enable or disable cookies, refuse all cookies or to indicate when a cookie is being sent.  Please note that by doing so you may not be able to use all the provided functions of our Website and/or Services in full.

We use the following cookies:

Strictly Necessary Cookies
These are cookies that are required for the operation of Our Site. They include, for example, cookies that enable you to log into secure areas of our website.
Analytics and Performance Cookie
We use third party analytics providers, such as Google Analytics to collect information about the usage of our services and enable us to improve how these services work, for example, by ensuring that users are finding what they are looking for easily.
Functionality Cookies.
These are used to recognise you when you return to Our Site. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
Targeting Cookies
We use third party targeting tools, such as LinkedIn Insights and ads tags. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests

Please see our Cookies Notice for further details

8. How might we share your personal data

We may disclose data that concerns you only if (i) we are legally required to do so; (ii) if required when you expressly order us to process a transaction or any other service and (iii) it is required for the provision of our Services under our contractual relationship and/or (iv) protection of our legitimate interests, in accordance with the provisions of the GDPR and applicable local legislation as amended from time to time.

We may share your personal data in the following circumstances, the following are examples of where and how your information may be transferred, but please note this is not an exhaustive list and that due to ongoing changes in our IT and operational infrastructure this may change at any time we may share your data between the NULLKER  on a confidential basis in order to provide you with our Services. 

A. Social Media. We use social media platforms in variety of ways and our legal relationship with each platform varies with the particular way we use the platform. We process your personal information using social media platforms in a variety of ways, as follows:

Pages. We use your personal information when you post content or otherwise interact with us on our official pages Facebook, Instagram, Twitter, LinkedIn and other social media platforms. We also use the Page Insights service for Facebook, Instagram and LinkedIn to view statistical information and reports regarding your interactions with the pages we administer on those platforms and their content.  Where those interactions are recorded and form part of the information we access through the Page Insights services, we and the relevant platform are joint controllers of the processing necessary to provide that service to us.

Single sign-on. Our Site incorporates a feature provided by social media and other digital service providers that allows you to join our Platform and create a User profile on this Website using the same login you have already set up with those providers. This feature is known as a ‘single sign-on service’.  Any use we make of the personal information we receive from the social media platform using this feature is processing for which we are the sole controller.

Data from your profile. When you use single sign-on services, you will be prompted to confirm that you are happy to share with us your email address and certain other personal information you hold with those providers.  You may be asked if you would like to share information with us that goes beyond what is needed to log you into your account on our Website. For example, you may be asked if you would like us to use your contact details or date of birth for direct marketing purposes. We will only use your personal information in this way if you agree.

Targeted advertising. We use social media platforms (as well as search engines and third party websites and other platforms) to deliver targeted advertising to you via those platforms, unless you object.  You may receive advertising because you have previously interacted with us (such as by visiting one of our Sites) or because of your profile on a social media platform on which you have an account. You can find our more by consulting the help pages of the relevant social media platform but in summary we use social media platforms to send targeted advertising using two main methods:

  • ‘Custom audience’ targeting.  You may receive advertising based on information about you that we have provided to the platform or allowed it to collect using cookies/pixels or code embedded in our Website (or a combination of the two).  For example, we may target you if you have signed up to our mailing list and where cookies have detected that you have visited our Website in the last month.  Please see the paragraph below regarding our use of cookies to send targeted advertising using social media.
  • ‘Lookalike audience’ targeting.You may also receive advertising because, at our request,  the social media platform has identified you as falling within a group or ‘audience’ whose attributes we have selected, or a group that has similar attributes to you (or a combination of the two).

Our relationship with social media platforms. As we are joint controllers/controllers with these platforms for certain processing, we and each platform have taken some or all of the following steps, depending on the platform:

  • entered into agreements in which we have agreed each of our data protection responsibilities for the processing of your personal information described above;
  • agreed that we are responsible for providing to you the information in this privacy statement about our relationship with each platform; and
  • agreed that each platform is responsible for responding to you when you exercise your rights under data protection law in relation to that platform’s processing of your personal information as a joint controller.

Facebook, LinkedIn and Twitter also process, as our processors, personal information that we submit for the purposes of matching, online targeting, measurement, reporting and analytics purposes.  These services include the processing these platforms carry out when they display our advertisements to you in your social media feed at our request after matching contact details for you that we have uploaded to them.  These advertisements may include forms through which we collect contact information you give to us.

Further information.The Facebook company that is a joint controller of your personal information is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The LinkedIn company that is a joint controller of your personal information is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.   The Twitter company that is a controller of your personal information is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland.  For further information regarding these platforms and their use of your personal information, please see:

B. Service Providers. We may share your personal data with our trusted third party service providers, who, on our behalf, operate, maintain, and/or support our IT systems and IT infrastructure, our websites, manage our payment solutions, perform statistical analysis, marketing and advertising purposes, sending newsletters, provide customer support and perform other important services for us. We will store and process your data following industry best practice and security.

When your personal data is shared with a third party, we will take the necessary steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.   We ensure that our contracts with those third parties contain the appropriate GDPR model clauses and that all our third parties are also compliant with the GDPR, this affords your data the same protection away from our organisation, as it does within it. Your personal data is shared with third party organisations/entities including but not limited to:

C. Governmental and state authorities. The Company will make such disclosure only if required to be disclosed by the Company by applicable law, regulation or court order and to the minimum required extent.

D. Other disclosures. In addition to where you have consented to a disclosure of the data or where disclosure is necessary to achieve the purpose(s) for which, it was collected, data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defence of legal claims.

Where reasonably possible, management shall ensure that third parties collecting, storing or processing personal information on behalf of the Company have:

  • Signed agreements to protect personal information consistent with this Privacy Notice and information security practices or implemented measures as prescribed by GDPR;
  • Signed non-disclosure agreements or confidentiality agreements which includes privacy clauses in the contract; and/or
  • Established procedures to meet the terms of their agreement with third party to protect personal information.

E. International Transfers. We process data within the EEA and countries deemed by the European Union as having adequate safeguards for protecting personal data. These countries are recognised by the EU as having suitable safeguards for the rights and freedoms of individuals and recourse processes by which data subjects can exercise their rights.

Should there be a business need to transfer or process your data to company(ies) and/or third parties might imply a transfer of your data to third countries, countries or regions which do not offer the same level of protection as the laws of your country (for example GDPR)(so called Third Countries) we will ensure that they are subject to appropriate security measures and safeguards as deemed appropriate under GDPR and other relevant national and international data protection laws or that we otherwise comply with the requirements and standards under Regulation 2016/679 for transferring Personal Data abroad. This may include entering into the appropriate contractual agreements to regulate any such transfers and safeguard any personal information transferred to them.  A transfer to a company and/or third party based in a Third Country would only take place where one of the following applies:

  • The individual has given consent to the transfer of information
  • The transfer is necessary for the performance of a contract between the individual and the Company, or the implementation of pre-contractual measures taken in response to the individual’s request.
  • The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between the NULLKER  and a third party.
  • The transfer is necessary or legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
  • The transfer is required by law.
  • The transfer is necessary in order to protect the vital interests of the individual.
  • The transfer is made under a data transfer agreement.
  • The transfer is otherwise legitimised by applicable law.

Remedial action shall be taken in response to misuse or unauthorized disclosure of personal information by a third party collecting, storing or processing personal information on behalf of NULLKER .

If you want to obtain further information on any data transfers mentioned above please contact us using the registered email address you disclosed to us through the points of contact listed in the Section OUR CONTACT DETAILS.

9. Your rights

Under certain circumstances in accordance with GDPR and the applicable local legislation as amended from time to time you have rights, which we will always work to uphold. Some of the rights are rather complex and include exemptions, thus we strongly advise you to contact us (at the contact details listed in the section OUR CONTACT DETAILS below) and/or seek guidance from the regulatory authorities for a full explanation of these rights. You can find a summary of your rights below in this section:

  • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
  • The right to access the personal data we hold about you.  Upon request and verification of your identity, we will send you a copy of the personal data we hold about you.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.  It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed if we have that data.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.  We may not always be able to comply with your request of erasure for specific legal reasons, for which you will be notified.  Please note that retention requirements supersede any right to erasure requests under the data protection laws.
  • The right to restrict (i.e. prevent) the processing of your personal data.  Please note that any requests in relation of the processing of your data means that we may not be able to provide you with the service, in which case you will be notified.
  • The right to object us in using your personal data for a particular purpose or purposes.
  • The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

10. Contact us

NULLKER  only processes your personal data in compliance with this Privacy Notice and in accordance with GDPR, while meeting highest possible data protection standards, and as such, we treat data protection complaints with all seriousness. So, should you have any reservations or complaints as to how we process(ed) your personal data, you can contact us through the following address:

Full Name of Legal Entity:


Email Address:

Postal Address:

Kolonakiou 42, Agios Athanasios 4103, Limassol Cyprus 

To enable us to process your request, please contact us using the registered email address you disclosed and registered with us. We may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification. This is to ensure that we appropriately protect the personal data we hold from unauthorised access requests and comply with our security obligations.

If you have any questions, or want more details about how we use your data, you may contact us at the above contact details and we will be happy to provide you with further details.

If following your request to us we are unable to provide you with a satisfactory answer then you may lodge a complaint with the local data protection supervisory authority. The data protection supervisory authority in Cyprus is: Commissioner for Data Protection P.O. Box 23378, 1682 Nicosia, Cyprus-

We would however appreciate the chance to deal with your concerns before you approach the GRA, so please contact us in the first instance.  

11. Links to other websites

We may provide links to third party websites in our Website. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our websites, including without limitation to the collection or disclosure of your data. Before disclosing your data on any other website, we encourage you to examine the terms and conditions of using that website and its privacy policies.

12. Changes to this privacy notice

This Privacy Notice was last updated 04 August 2023.

We have the right, at our discretion, to change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection and in order to ensure that the information herein provides relevant and adequate information about our collecting and processing of your data.

In case of any changes will be posted on the revised Privacy Notice on our Website Changes will take effect as soon as the revised version is made available on our website above. We recommend that you check the Website regularly to keep up-to-date. Your comments and feedback are always welcome. You may contact us at any time through the points of contact listed in the Section OUR CONTACT DETAILS above.

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