Privacy Policy

Effective date: 02/12/2025
This Privacy Policy (the “Policy”) describes how BESMARTKIDS LTD, a company incorporated under the laws of the Republic of Cyprus under registration number HE455383 (the “Company”), processes personal data when users access and use the website www.besmartcy.com and related online services.

The processing of personal data is carried out in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR) and applicable laws of the Republic of Cyprus.

For any questions regarding the processing of personal data, please contact: privacy@besmartcy.com

1. Categories of Personal Data Processed

The Company may process the following categories of personal data voluntarily provided by users:

• Parent’s (Customer’s) first and last name;
• Child’s first and last name;
• Contact phone number;
• Email address;
• Child’s age (if provided);
• Delivery address (for physical products);
• Information required to provide digital materials (email address, phone number, or account details);
• Any other information voluntarily provided by the user when contacting the Company.

Orders and Payments
For payments, the Company receives only technical transaction information from payment service providers, including:

• transaction identifier;
• payment amount;
• payment status.

The Company does not process or store bank card details.

Automatically Collected Data
The website may automatically collect:

• IP address;
• browser and device information;
• website usage statistics;
• cookies and similar technologies.

The Company does not process special categories of personal data as defined in Article 9 of the GDPR.
This Policy does not apply to third-party platforms that act as independent data controllers.
Cookies and Similar TechnologiesThe website uses cookies to ensure proper operation, improve functionality, and analyse website performance.

• Necessary cookies are used based on the Company’s legitimate interests.
• Analytics and marketing cookies are used based on user consent where required.

Users may change cookie settings through their browser or device settings.

2. Purposes of Personal Data Processing
Personal data is processed for the following purposes:

• providing the Company’s services;
• processing and fulfilling orders;
• providing digital materials;
• communicating with users;
• sending newsletters and marketing communications where consent has been provided;
• handling user requests and inquiries;
• complying with legal obligations;
• maintaining and improving website functionality.

3. Legal Basis for Processing
The Company processes personal data based on the following legal grounds:

• Performance of a contract or steps taken at the user’s request — Article 6(1)(b) GDPR;
• User consent — Article 6(1)(a) GDPR (for newsletters and certain types of communication);
• Legitimate interests — Article 6(1)(f) GDPR (security, website analytics, and service improvement);
• Legal obligations — Article 6(1)(c) GDPR.

4. Sharing of Personal Data
Personal data may be shared with:

• payment service providers (technical transaction information only);
• delivery service providers;
• email marketing and communication service providers;
• hosting providers and CRM systems;
• contractors involved in providing services;
• government authorities where required by law.

The Company does not sell or transfer personal data to third parties for commercial purposes.

5. International Transfers of Personal Data
If the Company uses service providers with infrastructure located outside the European Economic Area (EEA), it ensures that personal data transfers comply with GDPR requirements, including the use of Standard Contractual Clauses (SCCs) or other legally approved safeguards.

6. Data Retention Period
Personal data is stored only for as long as necessary to fulfil the purposes of processing or for periods required by the laws of the Republic of Cyprus.
Once processing is no longer required, personal data is deleted or anonymised.
7. Rights of Data SubjectsUsers have the right to:

• access their personal data;
• request correction of inaccurate data;
• request deletion of data;
• request restriction of processing;
• object to processing;
• request data portability;
• withdraw consent at any time;
• submit a complaint to the relevant supervisory authority.

Supervisory Authority:Office of the Commissioner for Personal Data Protection (Cyprus)
https://www.dataprotection.gov.cy/
Requests may be submitted to:
privacy@besmartcy.com

8. Data Security Measures
The Company implements appropriate technical and organisational measures to protect personal data, including access restrictions for employees and the use of secure information systems.

9. Changes to This Policy
The Company reserves the right to update this Privacy Policy.
The latest version is always available on the website and becomes effective from the date of publication.
The update date is indicated at the beginning of the document.

10. Company Details

BESMARTKIDS LTD
Registration number: HE455383
Registered address: Sotiri Tsagkari 17, 7060 Larnaka, Cyprus
Email: privacy@besmartcy.com
Website: www.besmartcy.com