Privacy Notice
How we handle personal data under the GDPR and Cyprus Law 125(I)/2018
This Privacy Notice is provided in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (General Data Protection Regulation — "GDPR") and the Cyprus Law 125(I)/2018 Providing for the Protection of Natural Persons With Regard to the Processing of Personal Data and for the Free Movement of Such Data.
1. Data Controller
Triwer Ltd Lordou Vyronos 61-63 6th floor, Flat/Office 602 6023 Larnaca, Cyprus E-mail: [email protected]
Triwer Ltd is the controller responsible for the processing of personal data described in this Privacy Notice. For all questions relating to this Privacy Notice or to exercise any of your rights, please contact us at the postal or e-mail address above.
2. Personal Data We Process and Why
2.1 Participation Data
•Data categories: name, e-mail address and any additional information you provide in the participation form. Where required for individual promotions, additional information such as place of residence, age or preferred redemption location may be processed.
•Purpose: processing participations in our promotions and services, managing voucher issuance, verifying eligibility and communicating in connection with the respective campaign.
•Legal basis: Article 6(1)(b) GDPR (performance of a contract).
2.2 Server Log Files
•Data categories: IP address, date and time of access, browser type and version, operating system, referrer URL and other technical data.
•Purpose: ensuring the technical availability, stability and security of our website.
•Legal basis: Article 6(1)(f) GDPR (legitimate interests). Our legitimate interest is the reliable operation and security of our website.
2.3 Cookies
The website triwer.ltd itself does not set cookies of its own and uses no analytics or marketing cookies.
Campaign websites operated by Triwer Ltd may use cookies to extend functionality and improve usability. The following types of cookies may be employed there:
•Strictly necessary cookies (legal basis: Article 6(1)(f) GDPR).
•Analytics and marketing cookies, used only with your consent (legal basis: Article 6(1)(a) GDPR). You can withdraw your consent at any time via the cookie banner of the respective campaign website.
These practices follow the requirements of Article 5(3) of Directive 2002/58/EC (e-Privacy Directive) as implemented in Cyprus by Law 112(I)/2004.
2.4 Contact Form
•Data categories: name, e-mail address, company or venue, telephone number (optional) and the content of your message.
•Purpose: handling your enquiry and any follow-up correspondence.
•Legal basis: Article 6(1)(b) GDPR where your enquiry relates to a contract or to steps prior to entering into one, otherwise Article 6(1)(f) GDPR. Our legitimate interest is responding to enquiries addressed to us.
The contact form is operated by Formspree, Inc., USA, which receives the submitted data on our behalf and forwards it to us by e-mail. Formspree processes the data on our behalf as a processor within the meaning of Article 28 GDPR. Where personal data are transferred to the United States, this is done on the basis of appropriate safeguards under Chapter V GDPR, in particular the European Commission’s standard contractual clauses (Article 46(2)(c) GDPR) or, where the recipient is certified under the EU-U.S. Data Privacy Framework, the adequacy decision of the European Commission.
3. Recipients of Personal Data
We share personal data with technical service providers (including the provider of our contact form), hosting providers, consent and cookie providers and, where required, campaign partners or participating partner venues only to the extent necessary to carry out the respective promotion, issue vouchers or technically provide our services. Where service providers act on our behalf, processing is carried out under a data-processing agreement compliant with Article 28 GDPR.
Legal basis: Article 6(1)(b) or (f) GDPR.
4. Storage Period
We retain personal data only for as long as necessary to provide our services or as required by statutory retention obligations. Participation data are generally deleted after completion of the respective campaign unless longer retention is required by law or documentation obligations. Enquiries received through the contact form are kept for as long as necessary to handle them and for any follow-up correspondence, unless statutory retention obligations require longer storage. Server log files are stored for security purposes and are anonymised or deleted after a few weeks.
5. Data Security
We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, destruction or manipulation. These measures are reviewed regularly and adjusted to the state of the art.
6. Your Rights
You have the following rights under the GDPR:
•Right of access (Article 15).
•Right to rectification (Article 16).
•Right to erasure ("right to be forgotten", Article 17).
•Right to restriction of processing (Article 18).
•Right to data portability (Article 20).
•Right to object (Article 21).
•Right to withdraw consent at any time (Article 7(3)).
7. Contact for Data Protection Matters
If you have any questions or wish to exercise your rights, please contact us at the address provided in Section 1.
8. Right to Lodge a Complaint
You can lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement. In Cyprus the competent authority is the Office of the Commissioner for Personal Data Protection, 1 Iasonos Street, 1082 Nicosia (www.dataprotection.gov.cy, e-mail: [email protected]).
9. Updates to This Privacy Notice
We may update this Privacy Notice from time to time to comply with legal requirements or to reflect changes in our services. The current version will always be available on our website.
(Last updated: September 2026)