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Privacy policy

How Varinomics Ltd processes personal data through varinomics.com.

This policy describes how Varinomics Ltd processes personal data through the varinomics.com website. Product-specific processing at customer premises is governed by each product's deployment documentation and, for Phylax, by the Phylax Data Processing Agreement.

Data controller

Varinomics Ltd
Agiou Athanasiou 59
4102 Limassol, Cyprus

Contact: [email protected]
Company registration: HE 434980. VAT: CY10434980X.

Scope

This policy applies to varinomics.com and its subdomains. Customer systems running Varinomics software on their own infrastructure are governed by the applicable commercial agreement and, where personal data is processed on behalf of a customer, by a separate data processing agreement.

Data collected by this website

The website is built without analytics, advertising, or tracking.

  • Only the cookies minimally required by the static framework to serve pages are set.
  • Fonts are served from the site's own origin.

Email contact

Visitors reach us by email at [email protected]. When you email us, we process the content of your message together with any personal data it contains - typically your name, email address, any organisation you mention, and the content of your message.

Lawful basis Art. 6(1) GDPR

  • Art. 6(1)(b) - processing is necessary for taking steps at the request of the data subject prior to entering into a contract (product-evaluation, procurement, and consulting enquiries).
  • Art. 6(1)(f) - legitimate interest of Varinomics in responding to correspondence addressed to the company (general, support, and other non-pre-contractual enquiries). You may object to this processing under Art. 21 GDPR.
Sub-processor
Email is received and stored through the email provider we use for our @varinomics.com mailboxes (see Sub-processors below).
Retention
Correspondence is retained for up to 24 months after the last substantive reply, unless a commercial relationship or a legal obligation requires a longer retention. You may request deletion at any time by replying to the email thread or by writing to [email protected].

Server logs and hosting

The site is served as static files. GitHub, Inc. (GitHub Pages) hosts the static files; its log practices are governed by GitHub's own policy. Transient access metadata (IP address, user agent, requested URL, timestamp) may be recorded by the hosting provider for operational and abuse-prevention purposes.

Lawful basis Art. 6(1) GDPR

Art. 6(1)(f) - legitimate interest in operating and securing the website.

International transfers

Some service providers we use are established outside the European Economic Area:

  • GitHub, Inc. (United States) - website hosting.
  • Google LLC (United States) - Google Workspace; mailbox hosting.

Where personal data is transferred to the United States, such transfers are safeguarded under the European Commission's adequacy decision for the EU-US Data Privacy Framework and, as an alternative, under Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. Both GitHub and Google are certified under the EU-US Data Privacy Framework. Google's provider-specific privacy framework information is published at Google privacy frameworks; GitHub's provider policy is the GitHub Privacy Statement.

Sub-processors

  • Hosting provider - GitHub, Inc. (GitHub Pages). Purpose: static website hosting.
  • Email provider - Google LLC (Google Workspace). Purpose: mailbox hosting for @varinomics.com addresses.

Data residency

The static website and its served files are hosted on GitHub Pages infrastructure (United States). We perform no additional data storage on behalf of this website.

Your rights under the GDPR

You have the following rights under the official GDPR text:

  • request access to the personal data we hold about you (Art. 15)
  • request rectification of inaccurate data (Art. 16)
  • request erasure (Art. 17)
  • request restriction of processing (Art. 18)
  • object to processing based on legitimate interest (Art. 21)
  • data portability (Art. 20)
  • where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal (Art. 7(3))

Exercise any of these rights by emailing [email protected].

You also have the right to lodge a complaint with a supervisory authority. The lead supervisory authority for Varinomics is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus. EU data subjects may also complain to their local supervisory authority.

Automated decision-making

This website does not perform automated decision-making within the meaning of Art. 22 GDPR.

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