Διεύθυνση: Δήμος Αθηένου Λεωφ. Μακαρίου Γ΄, Αρ. 2, 7600 Αθηένου Κύπρος 
Τηλ.: +357 24811370
Ε-mail: 
What is the purpose of this document?
Municipality of Athienou (hereinafter referred to as “the Organisation” or “us”, is committed to protecting the confidentiality and security of your personal data under the General Data Protection Regulation of the EU 2016/679 (“GDPR”) and the Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125 (I) / 2018).
This data protection and confidentiality policy describes how we collect, manage, use and process your personal information during your use and browsing of www.athienou.org.cy or in connection with any of your dealings with our Organisation or to subscribe to our newsletter.
Municipality of Athienou is a “data controller”. This means that we are responsible for deciding how your personal data is stored and used. We are obliged in accordance to by laws to provide you with the information contained in this data protection and confidentiality policy.
This policy applies to every user of our website, as well as to any user who provides personal data through our website or provides personal data in any other way to our Organisation. This policy is not part of any services contract or any other contract. We may amend, update and/or replace this policy from time to time.
It is important that you read this policy along with any other privacy statements we may provide in specific instances when we collect or process personal information about you, so that you know when, how and why we use this information.
Introduction
This Data Protection and Confidentiality Policy (hereinafter referred to as the “Privacy Policy”) of the Municipality of Athienou (hereinafter referred to as the “Municipality of Athienou” or “we”) provides an overview of the manner in which the Municipality of Athienou processes personal data of natural persons. This Privacy Policy is of relevance or/and is addressed to you if:
– You are a citizen of the Municipality of Athienou
– You are an employee of the Municipality of Athienou
– You are an associate/procurer of the Municipality of Athienou
– You are a member of the board of the Municipality of Athienou
– You are a volunteer of the Municipality of Athienou
– You are or have or will have any transaction, of any nature and for any reason, with the Municipality of Athienou (submission of applications, complaints, transfer of your professional seat to the Municipality of Athienou, etc.)
Municipality of Athienou, is committed to protecting the confidentiality and security of your personal data under the General Data Protection Regulation EU 2016/679 (“GDPR”) and the Law for providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (L. 125(I)/2018), as amended.
Any data processing in the Municipality of Athienou is carried out based on the provisions of the GDPR, Law 125(I)/2018, as well as in accordance to the duties and obligations that the Municipality of Athienou must abide by in with accordance with the Municipalities Law of 2022, Law 52(I)/2022, as amended.
This Privacy Policy describes how we collect, manage, use and process your personal information during your use and browsing of the website www.athienou.org.cy or in connection with any of your dealings with our municipality or to subscribe to our newsletter.
Municipality of Athienou is a “data controller”. This means that we are responsible for deciding how your personal data is maintained and used. We are obliged, under the applicable legislation regarding the protection of personal data, to provide you with the information contained in this Privacy Policy.
The categories of personal data processed by the Municipality of Athienou, are determined by the type of service for which you contact the Municipality of Athienou and by the nature of the relationship maintained in this context.
This Privacy Policy applies to every user of our website, as well as to any user who provides personal data through our website or provides personal data in any other way to our municipality. This Privacy Policy is not part of any services contract or any other contract. We may amend, update and/or replace this Privacy Policy from time to time.
It is important that you read this Privacy Policy, along with any other privacy statements which we may provide in specific instances, when we collect or process personal information about you, so that you know when, how and why we use this information.
Data protection principles
Municipality of Athienou undertakes to comply with the principles related to the processing of personal data set by the GDPR. These principles state that the personal information we hold about you must:
- Be processed lawfully and fairly, in a transparent manner.
- Be collected only for specified, explicit and legitimate purposes which we have clarified to you and are not processed in a manner that is incompatible with those purposes.
- Be relevant to the purposes we have informed you about and are limited to those purposes only.
- Be accurate and kept up to date.
- Be kept for as long as necessary for the purposes we have informed you.
- Be kept safe.
Who is responsible for processing of your Personal Data
Your personal data will be retained and/or processed by the Municipality of Athienou. If you have any questions regarding this Privacy Policy, please contact us in the following ways:
– Address: Municipality of Athienou, Makariou III Avenue, No. 2, 7600 Athienou, Cyprus
– Telephone No.: +357 24440192
– Data Protection Officer email address: dpo@athienou.org.cy
GDPR legal basis for the use of personal information
We shall only use your personal data in accordance with the GDPR legal bases set out below. Typically, we shall use your personal data in the following instances:
- Where processing is necessary for the fulfilment of our duty which is performed in the public interest or in the exercise of official authority vested in us.
- Where we are taking steps prior to the conclusion of a contract at your request or where processing is necessary for the performance of a contract to which you are a party.
- When processing is necessary for the fulfilment of a statutory obligation.
- In case you have explicitly asked us to do something or when you have given us your consent to process your personal data (e.g. answer a question or complaint you may have asked us or to subscribe to our newsletter).
We may also use your personal information in the following instances, which may be less usual:
- Where processing is necessary for the satisfaction of our legitimate interest or that of a third party, in which the data is disclosed, which (interest) overrides your rights and interests.
- Where necessary to protect your vital interests or those of another natural person.
Specific purposes for which we may use your personal data
The table below summarises the main purposes for which we process your personal data, the type of personal data we collect for each purpose and the legal basis on which we process that personal data. Some of the above cases overlap and there may be different bases that justify the use of your personal data.
| A/A | Purpose of Processing | Personal Data collected | Legal basis |
| 1. | Maintaining a Register of Citizens (regarding every person who has the status of Citizen in the Municipality of Athienou). | Name and Surname, ID number, address, mailing address, email, telephone number | – Public interest – Legal obligation (article 10 of the Municipalities Law of 2022, Law 52(I)/2022) -Legitimate interests |
| 2. | Creation and maintenance of a record with personal data of callers at the call centre of the Municipality of Athienou. | Name and Surname, telephone number, the matter of communication | Person’s consent |
| 3. | Creation and maintenance of a personal data record for the purpose of sending invoices via email. | Name and Surname, telephone number, email, physical address | Person’s consent |
| 4. | Creation and maintenance of a record of volunteers’ personal data. | Name and Surname, address, telephone number (mobile/landline), email, areas of interest | Person’s consent |
| 5. | Creation and maintenance of a Neighbourhood Observer personal data record. | Name and Surname, address, telephone number, email, area of interest | Person’s consent |
| 6. | Creation and maintenance of a record with data of data subjects, to whom information is sent regarding promotional actions, updates, etc. via text messages (SMS) and/or electronically and/or for the purposes of sending the newspaper of the Municipality of Athienou to non-residents and/or expatriates. | Name and Surname, mailing address, telephone | Person’s consent |
| 7. | Creation and maintenance of a record of Civil Marriages and/or updating of the Marriage Registry. | Name and Surname, ID number, date of birth, marital status (divorced, widowed), citizenship, place and residential address, full names of parents, full names and ID numbers of witnesses, date of marriage, type of marriage | – Public interest – Legal obligation of the Municipality (Marriage Law of 2003 (L. 104(I)/2003)) |
| 8. | Creation of a record with the personal data of data subjects who submitted a request and/or complaint to the Municipality of Athienou. | Name and Surname, information depending on the content of the complaint and what the complainants themselves have chosen to report. | – Person’s content – Legal Obligation of the Municipality (article 78 of the Municipalities Law of 2022, Law 52(I)/2022) |
| 9. | Creation and maintenance of a personal data record for the purpose of monitoring the navigation history of website visitors, through Google Analytics. | IP Address | Person’s consent |
| 10. | Creation and maintenance of a record with the personal data of the members of the board of the Municipality of Athienou. | Name and Surname, telephone, mailing address, email | Legitimate interests (fulfilment of legal obligations of the Municipality) |
| 11. | Processing, storage, publication of personal data of the members of the board of the Municipality of Athienou regarding the agendas of the Municipal Board and the minutes of its meetings. | Name and Surname, any personal data contained in said documents | – Legal obligation (articles 14,65 and 79 of the Municipalities Law of 2022, Law 52(I)/2022) – Legitimate interest of the Municipality (fulfilment of legal obligations of the Municipality) – Public interest |
| 12. | Creation and maintenance of a record with personal data regarding the imposition of fees (permits, real estate tax, garbage collection fees, etc.) to citizens. | Name and Surname, ID Number, father’s name, real estate details, date of ownership, plot area, plot value, telephone number, mailing and plot address, nature of business, etc. | – Legal obligation (articles 46, 104- 106 and 108 of the Municipalities Law of 2022, Law 52(I)/2022), article 30, L. 4/1978 – Legitimate interest of the Municipality (fulfilment of legal obligations of the Municipality) – Public interest |
| 13. | Creation and maintenance of a file with personal data regarding the receipt, examination and issuance of decisions regarding the handling of tax objections for reduced invoicing. | Name and Surname, ID number, date of birth, address, supporting documents (health data) or depending on the content of the letter of objection. | – Legal obligation (articles 46 of the Municipalities Law of 2022, Law 52(I)/2022) – Legitimate interest of the Municipality – Public interest For special categories of data: -Person’s consent -Necessary processing for the performance of the Municipality’s obligations |
| 14. | Creation and maintenance of a personal data record regarding the submission, receipt, examination of an application and issuance of a professional premises operating permit. | Name and Surname, ID number, residential address, mailing address, telephone number, property name, company details, property telephone number, property type, property details. | – Legal obligation (articles 56, of the Municipalities Law of 2022, Law 52(I)/2022), article 30, L. 4/1978 – Legitimate interest of the Municipality – Public interest |
| 15. | Creation and maintenance of a personal data record regarding the submission, receipt, examination of applications and issuance of permits for placing and posting advertisements, permits for the sale of alcoholic beverages, sound emission permits, permits for operating recreational areas, tobacco permits, permits for operating a petroleum service station, and excavation permits. | -For natural person applicants: Name and Surname, ID number, residential address, mailing address, company details, telephone, property name, property telephone, property type, property details, pictures, Clean Criminal Record. – For legal person applicants (for a legally responsible person): Name and Surname, ID Number, mailing address, telephone, Clean Criminal Record. |
– Legal obligation (articles 45-45, of the Municipalities Law of 2022, Law 52(I)/2022), article 30, L. 4/1978 – Legitimate interest of the Municipality (fulfilment of legal obligations of the Municipality) – Public interest |
| 16. | Creation and maintenance of a personal data record for the purpose of imposing charges for plots cleaning in the context of nuisance removal, sending charges and collection of the relevant fees. | Name and Surname, mailing address, property address, email, telephone. | – Legal obligation (articles 118-119, 121, 123-125, 129 of the Municipalities Law of 2022, Law 52(I)/2022), article 30, L. 4/1978 – Legitimate interest of the Municipality (fulfilment of legal obligations of the Municipality) – Public interest |
| 17. | Creation and maintenance of a personal data record regarding the submission, receipt, examination of an application and issuance of a street vendor/fair permit. | Name and Surname, ID number, Telephone, Mailing Address | – Legal obligation (articles 59 of the Municipalities Law of 2022, Law 52(I)/2022), article 30, L. 4/1978 – Legitimate interest of the Municipality (fulfilment of legal obligations of the Municipality) – Public interest |
| 18. | Creation and maintenance of a personal data record. regarding the submission, receipt, examination of an application and issuance of a dog ownership permit. | Name and Surname, ID number, address, telephone, fax number, email, occupation, shepherd / breeder / blind person, dog category.
For trainers: |
– Legal obligation (articles 44 of the Municipalities Law of 2022, Law 52(I)/2022), article 3 of the Law 184(I)/2002) – Legitimate interest of the Municipality – Public interest For special categories of data: – Person’s consent – Necessary processing for the performance of the Municipality’s obligations |
| 19. | Creation and maintenance of a record with personal data regarding the agreements for the repayment of overdue debts to the Municipality of Athienou. | Name and Surname, address, ID number | – Legal obligation (article 30(2), L. 4/1978 – Necessary processing for the performance of a contract – Public interest |
| 20. | Creation and maintenance of a personal data record regarding the process of receipt, assessment and notification of a decision regarding the offers submitted to the Municipality of Athienou. | Natural persons: Name and Surname, ID number, passport number, address, country of establishment, telephone number, fax, VAT registration number. Legal persons: Name and Surname of contact person |
– Legal obligation (articles 49(6) and 131(4) of the Municipalities Law of 2022, Law 52(I)/2022), article 3 of the Law 184(I)/2002) – Legitimate interest of the Municipality (fulfilment of legal obligations of the Municipality) – Public interest |
| 21. | Creation and maintenance of a file of personal data of participants in social and/or cultural events of the Municipality of Athienou. | Name and Surname, Telephone number, Email, Capacity, photo | Person’s consent |
Non provision of personal data
If you do not provide specific information when requested to do so, we may not be able to fulfil our duty to consider an application you have submitted to us or contract with you to provide you with a service, or we may be prevented from complying with our legal obligations.
Change of purpose
We will use your personal data only for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that reason is compatible with the original purpose. If we need to use your personal data for any purpose not related to the original purpose, we will notify you and explain the legal basis which allows us to do so. We may process your personal data without your knowledge or consent, when required or permitted by law.
Right to withdraw consent
In the limited instances where you may have given your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent to this processing at any time. To withdraw your consent, please submit a request to the Data Protection Officer at dpo@athienou.org.cy. Upon receipt of notice that you have withdrawn your consent, we will no longer process your information for the purpose or purposes for which you originally agreed on the basis of your consent, unless we have another legal basis for doing so, in which case we will continue processing and inform you accordingly.
Automated decision-making
Automated decision-making occurs when an electronic system uses personal information to make a decision without human intervention. We have the ability to use an automated decision-making process in any of the following cases:
- When it is necessary to conclude or fulfil your contract with us.
- When permitted by law which also provides for appropriate measures to safeguard your rights, freedoms and legitimate interests, such as e.g. for citizens requesting a discount on any fees based on the information they provided.
- In limited cases, with your explicit written consent and where appropriate measures are in place to protect your rights.
If we make an automated decision on the basis of any special category of personal data, we must either have your explicit written consent, or it must be justified in the public interest, and we must also take appropriate measures to safeguard your rights.
You shall not be subject to decisions which have a significant impact on you based solely on automated decision-making, unless we have a legal basis for doing so and have notified you in advance.
Data sharing
We may need to disclose your information to third parties, including any of the service providers we work with. We require our third-party associates, where possible, to secure your data and treat it in accordance with the law.
Why can we share your personal information with third parties?
We may disclose your personal information to third parties, where required by law or where we have another legitimate interest in doing so.
Which third party service providers process my personal information?
“Third parties” include third party service providers (including consultants and authorised representatives). The following activities are performed by third party service providers: IT and software services, accounting, auditing and legal services.
How secure is my data with third party service providers?
All third-party service providers we work with, are required to take appropriate security measures to protect your personal data in accordance with our policies. We do not allow third party service providers to use your personal data for their own purposes. We only allow your personal data to be processed for specific purposes and in accordance with our instructions.
What about other third parties?
We may disclose your personal information to other third parties or you may disclose information to a third party because you have visited us or interacted with our website or our services. For instance, in the context of your interaction with certain functions which we use, such as the “Like” and “Share” button on Facebook and similar functions of other social media platforms e.g. Instagram, Twitter, etc., you may share your personal information with these third parties. We may also need to disclose your personal information to a regulatory authority or to comply with the law.
International data transfer
Upon receiving your consent, your personal data may be transferred outside the European Economic Area (EEA), however none of the service providers with which we work, are based outside the EEA. Whenever your personal data is transferred outside the EEA, we shall ensure that a similar degree of protection and appropriate guarantees are provided, and we shall ensure that when using non-EEA service providers, we shall use specific contracts approved by the European Commission, which provide to personal data the same protection offered within the EEA. Please contact us if you would like to receive more information about the specific mechanism we use when transferring your personal data outside the EEA.
Data Security
We have implemented measures to protect the security of your data, for example to back up and to protect the integrity of electronic communications and data storage systems.
Third parties may process your personal data only with our instructions and where it has been agreed to treat it confidentially and to maintain the source of the information.
Data retention - How long will you use my data?
We shall retain your personal data only for as long as it takes to fulfil the purposes for which we collected it. In order to determine the appropriate period of retention of personal data, we examine the quantity, nature and sensitivity of personal data, the potential risk of damage from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve these goals by other means and any applicable legal requirements.
In some cases, we may pseudonymise your personal information so that it can no longer be associated with you, so that we may use this information without further notice. As soon as the purposes for which we collected your data disappear, we will safely destroy your personal data in accordance with the Personal Data Retention and Disposal Policy of the Municipality of Athienou.
For more details regarding the retention period of your data in our files, you can contact the Data Protection Officer of the Municipality of Athienou at dpo@athienou.org.cy.
Access, correction, deletion and restriction rights
Your rights in relation to personal data
Under certain circumstances, you have the right to:
- Access your personal data. This allows you to obtain a copy of the personal information we hold about you and to verify that we are processing it legally.
- Correct personal information we hold about you. This enables you to correct any incomplete or inaccurate information we have about you. Please let us know once your personal information changes during your relationship with us.
- Delete your personal information. This allows you to ask us to delete or remove your personal information where there is no reason to continue processing it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to the processing (see below).
- Object the processing of your personal information, where we invoke a legitimate interest (or legitimate interest of a third party) and there is a reason for your particular situation that prompts you to oppose the processing for this reason.
- Non-automated individual decision-making, which concerns you and is made solely on the basis of automated processing, including the creation of an individual profile, which produces legal results that concern you or affect you in a similar way, where you do not consider such processing legal.
- Restrict the processing of your personal data. This allows you to ask us to suspend the processing of your personal information, for example if you wish to confirm the accuracy or the purpose of processing.
- Data portability. You can request the transmission of your personal information to another controller.
If you wish to exercise any of the above rights, please contact the Data Protection Officer at dpo@athienou.org.cy.
Data protection and complaints officer
In accordance with the GDPR, we have appointed as Data Protection Officer (DPO) the law firm E. TZIONI & ASSOCIATES LLC, to oversee compliance with this Privacy Policy. If you have questions regarding this Privacy Police or how we handle your personal data, please contact the Municipality of Athienou Data Protection Officer at dpo@athienou.org.cy. You have in any case the right to submit a complaint at any time to the Office of the Commissioner for Personal Data Protection, the supervisory authority for personal data protection issues of the Republic of Cyprus.
Data breaches
We shall report any data breach in the Municipality of Athienou within 72 hours of the breach if it appears that the personal data stored in a recognisable form has been breached.
COOKIES
Our website www.athienou.org.cy uses “cookies”, a technology which stores data on your computer or mobile phone, using the functionalities of your web browser, in order to collect statistics for visitors of its website. More information regarding the Policy in relation to the cookies of our Municipality is posted on our website.
Changes to this data protection policy
This Privacy Policy may be updated from time to time in accordance with legislation or general developments. We shall not explicitly inform our citizens or users of our website regarding these changes. Instead, we encourage you to periodically check this page for any Privacy Policy changes.
Acknowledgement and Acceptance
By continuing to use www.athienou.org.cy, you acknowledge that you have read, understood and agreed to the contents of this Privacy Policy.