PRIVACY AND COOKIE POLICY

This Privacy and Cookie Policy (“Policy”) applies to the processing of your personal data by APEXIA GROWTH LTD through “itstaff.io” and related domains (“Website”) in accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (as amended), Directive 2002/58/EC – ePrivacy Directive (as amended), and other applicable local laws ('Data Protection Laws').

1. Data Controller and Data Protection Officer

The Data Controller is APEXIA GROWTH LTD, with its registered office at Georgia, St. Tbilisi, Vake-Saburtalo district, Vazha Pshavela avenue, N 20, apartment N70. For any requests regarding the processing of your personal data, please email us at [email protected].

Our Data Protection Officer can be contacted for any requests relating to the processing of your personal data or this Policy by sending an email to [email protected].

2. Categories of personal data that we collect, purposes and legal bases for our processing

We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all the below information may be deemed personal data in your jurisdiction in all cases..

Purpose	Legal Basis	Categories of Processed Data
a. To enable you to use our Website.	Processing is necessary for the performance of a contract to which you are party (Art. 6(1)(b) of the GDPR).	ID e informazioni tecniche sul tuo dispositivo, dettagli del browser web, indirizzo IP e altre informazioni necessarie per il funzionamento del Sito Web.
b. To comply with our legal obligations.	Compliance with a legal obligation to which we are subject (Art. 6(1)(c) of the GDPR).	Any information necessary to ensure compliance with applicable laws.
c. To establish, exercise or defend our rights and those of our employees, and to carry out corporate transactions or operations.	The legal basis for the processing is our legitimate interest (Art. 6(1)(f) of the GDPR).	Any information necessary for legal and business purposes.
d. To process and respond to customer support communications and requests for information.	The legal basis for the processing is the performance of our contractual relationship (Art. 6(1)(b) of GDPR).	Identification and contact information you provide us, and the content of your request.
e. Creare profili utente analizzando preferenze, comportamenti, interessi e scelte espresse attraverso l'uso del Sito Web.	The legal basis for the processing is your consent (Art. 6(1)(a) of the GDPR).	Identifiers and Internet and network activity information (such as IP address).

3. Data Retention

Personal data will be kept for no more than:

3 years for the purposes referred to in Sections 2.a) and 2.d)
5 years for the purposes referred to in Section 2.b)
10 years for the purposes referred to in Section 2.c)
Until you withdraw your consent for the purposes referred to in Section 2.e)

4. Your Choices

Providing navigation data is necessary to use and interact with our Website. You can freely decide whether to accept cookies and tracking technologies as indicated in Section 8 (Cookies) below.

5. Sharing Your Personal Data

We may share your personal data with:

Service providers (e.g., IT, storage, advertising, and marketing providers).
Public authorities as required by law.
Advisors and potential purchasers in case of corporate transactions.

6. Transfer of Personal Data Outside the European Economic Area

Transfers are based on appropriate safeguards, including standard contractual clauses, adequacy decisions, or Binding Corporate Rules.

7. Your Rights

You can exercise your rights, including access, rectification, erasure, restriction, data portability, and objection, by contacting [email protected].

8. Cookies

We use technical, analytics, and profiling cookies. For more details on how we use cookies and how to manage your preferences, please refer to our Cookie Policy on our Website.

9. Changes

This Policy may be updated periodically.

Last updated: February 28, 2024.