1. Introduction

2. 1. This Privacy Policy („Policy“) explains how Xava-Xava Ltd. („Xava-Xava“ or „we“) handles personal data of subscribers or visitors to our website.

   2. We take the protection of your personal data very seriously and are committed to respecting and safeguarding your privacy. Xava-Xava will handle your data in compliance with applicable legal regulations and take appropriate measures to protect and keep your data confidential.

3. Personal Data Collected
   The information we collect may vary depending on the products and services you use, your relationship with us, and any data received from third parties. The personal data („Personal Data“) we may collect includes:

   1. Name, address, phone number, email address;

   2. Communication data, such as call logs;

   3. Information about your internet usage, such as time, duration, and approximate locations;

   4. Records of communications (phone calls, emails, letters);

   5. Location data obtained through GPS, Wi-Fi, or IP addresses;

   6. Your preferences and interests based on your use of our products and services.

We also collect information about your use of our services for purposes such as quality assurance and troubleshooting.

3. Methods of Data Collection
   We collect personal data in the following ways:

• During contract initiation or application processes;

• Via telephone, in person, or in writing;

• Through the use of our website or social media platforms;

• By participation in surveys, contests, or promotions;

• Through third parties with whom we collaborate.
  Cookies are used to ensure the functionality of our website. Details can be found in the „Cookies“ section.

4. Use of Personal Data
   We use your personal data for the following purposes:

   1. Providing products and services;

   2. Sending invoices and payment reminders;

   3. Informing you about news, offers, and promotions (only with your consent);

   4. Responding to your inquiries and complaints;

   5. Developing and improving our products and services;

   6. Analyzing your use of our offerings to provide personalized advertising (details in the „Cookies“ section);

   7. Preventing fraud and illegal activities;

   8. Managing data traffic and optimizing our networks.

5. Protection of Personal Data

   1. Xava-Xava will only share your data when legally required or with your explicit consent.

   2. Data will only be stored as long as legally required or necessary for the stated purposes.

   3. Your consent to data processing can be withdrawn at any time.

6. Processing of Personal Data
   Processing is carried out in accordance with the EU General Data Protection Regulation (GDPR) and national legislation. Legal bases include:

   1. Contract fulfillment;

   2. Compliance with legal obligations;

   3. Legitimate interests (e.g., fraud prevention);

   4. Your consent.

7. Duration and Storage of Data

   1. Data is stored within the EU and protected against unauthorized access.

   2. Upon contract termination, data is typically retained for two years unless legal requirements mandate a longer storage period.

8. Rights of Data Subjects
   You have the following rights:

   1. Access to your stored data;

   2. Correction of inaccurate data;

   3. Deletion of your data, unless legal reasons prevent this;

   4. Restriction of data processing;

   5. Data portability;

   6. Withdrawal of your consent;

   7. Objection to automated decisions.

9. Data Sharing
   Your data may be shared with:

• Service providers of Xava-Xava;

• Authorities, where legally required;

• External consultants such as lawyers and auditors;

• Partner companies for joint offers or promotions.
  Data sharing is always conducted in compliance with confidentiality and legal regulations.

10. Cookies
    Our website uses cookies to ensure functionality and enhance your user experience. You can disable cookies via your browser settings, but this may limit certain functions.

11. Changes to the Privacy Policy
    Xava-Xava reserves the right to amend this Privacy Policy. Changes will be published on our website.

12. Contact
    For questions or to exercise your rights, please contact us at:
    Email: info@xava-xava.com
    Address: Avlidos 7, Limassol 4042, Cyprus