Privacy Policy
Effective Date: 18/11/2024
Version 1.1.

Totemix Co Ltd. («we», «our», or «us»), a company duly registered in Cyprus under registration number HE442291 with registered address at 25 Martiou, 27 D. MICHAEL TOWER, Flat/Office 105A Egkomi, 2408, Nicosia, Cyprus with contact e-mail info@totemix.cy.

At Totemix Co Ltd. protecting your privacy is our priority. This Privacy Policy outlines how we collect, use, store, and protect personal data gathered through our website at https://totemix.cy/ (the «Website»). It also explains your rights regarding your data under applicable data protection laws, including the Cypriot Law on the Protection of Natural Persons with Regard to the Processing of Personal Data and the Free Movement of Such Data of 2018 (Law 125(I)/2018), including any amendments or related legislation, and The General Data Protection Regulation (EU) 2016/679 (GDPR).

By using our Website, you agree to the practices described in this Privacy Policy. If you do not agree, please refrain from using the Website.
1. Information We Collect

We collect and process the following categories of data:

1.1 Data Provided Directly by You:
Information you submit via forms on our Website, including your name, email address, phone number, company details, and any other information you choose to share.

1.2 Data Collected Automatically:
Technical information such as your IP address, browser type, operating system, geographic location, and browsing activity on the Website.

1.3 Data from Third Parties:
Information sourced from publicly available records or third-party providers to enhance our services or verify your business details.
2. Purpose of Processing

We process personal data for the following purposes:
  • Service Delivery: To respond to inquiries, provide requested information, and facilitate communication regarding our services.
  • Website Optimization: To improve the functionality, security, and user experience of the Website.
  • Compliance and Legal Obligations: To comply with regulatory requirements and enforce legal rights.
3. Legal Basis for Processing

We process personal data based on:
  • Your consent: When you voluntarily provide your information through Website forms or communications.
  • Legitimate Interests: For improving our services, securing our systems, and responding to inquiries.
  • Legal Obligations: To fulfill legal and regulatory requirements.
4. Data Retention

4.1 Retention Periods:
We retain personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy or to comply with legal obligations.

Contact data provided through inquiries is retained for the duration of our engagement and for a reasonable period thereafter.

4.2 Secure Disposal:
Once data is no longer required, we securely delete, anonymize, or aggregate it. If stored in backups, it remains protected until it can be securely removed.
5. Sharing Your Data

We may share your personal data in the following scenarios:
  • Service Providers: With trusted third parties providing IT support, hosting, or analytics services.
  • Legal Authorities: When required by law, regulation, or judicial process.
  • Business Transactions: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new owner, subject to this Privacy Policy.

We do not sell or rent your personal data to third parties for marketing purposes.


We may aggregate your personal data for statistical, research, or analytical purposes. Aggregated data refers to data that has been combined and anonymized in such a way that it cannot identify any individual. This data may be used to analyze trends, improve our services, and provide insights to our business partners. Aggregated data is not considered personal data and is not subject to the same privacy protections.


We may disclose your personal data when necessary to protect our legal rights, such as to comply with legal obligations, respond to court orders or government requests, defend against legal claims, prevent fraud or security threats, or during business transactions like mergers or acquisitions. Any such disclosures will be made in compliance with applicable data protection laws.

6. International Data Transfer

We may need to transfer personal data as part of our services to countries outside the European Economic Area (EEA), including but limited to our partners, subcontractors, or cloud providers. We take steps to ensure your data is protected during these transfers through the following methods:
  • Standard Contractual Clauses (SCCs), which legally bind parties to ensure your data is protected.
  • Binding Corporate Rules (BCRs), if applicable, for internal transfers within our organization.
  • Adequacy Decisions: If data is transferred to a country that has been deemed to provide adequate protection by the European Commission.
7. Your Data Protection Rights

You have the following rights concerning your personal data:
7.1 Right to Access: Request details of the data we process about you.
7.2 Right to Rectification: Request corrections to inaccurate or incomplete data.
7.3 Right to Erasure: Request the deletion of data no longer necessary for its original purpose or when you withdraw consent.
7.4 Right to Restrict Processing: Request limited processing in specific circumstances.
7.5 Right to Data Portability: Request your data in a machine-readable format or transfer it to another organization.
7.6 Right to Object: Object to data processing based on legitimate interests or for direct marketing.
7.7 Right to Lodge a Complaint: If you believe that we have infringed your rights, you have the right to complain to the Cypriot Data Protection Authority, which can be contacted at:

Office of the Commissioner for Personal Data Protection
Kypranoros 15, Nicosia 1061, Cyprus
Tel: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy

We encourage you to contact us first to seek a resolution before you lodge a complaint.
To exercise these rights, contact us using the details in Section 10.
8. Cookies and Tracking Technologies

8.1 Use of Cookies:
Our Website may use cookies and similar tracking technologies, which are small text files stored on your computer or device. Cookies are created by a web server, which is the system that manages a website, and stored on your device’s hard drive. They contain data that the server can access whenever you revisit the site, allowing it to recognize your preferences and interactions.

We utilize cookies to support the core functionality of our Website, store user preferences (such as your choices regarding tracking technologies), enhance the delivery of our services, optimize site performance, and provide content tailored to your interests. Additionally, cookies help us evaluate the effectiveness of our Website, marketing initiatives, and email communications while personalizing the overall user experience.

Our Website employs different types of cookies to improve functionality and user satisfaction:
Essential Cookies: These cookies are critical for the basic operation of the Website. Disabling them through browser settings may limit functionality or negatively affect performance.

Functional Cookies: Designed to provide additional features and customization, these cookies may be managed by us or third-party providers integrated into the Website.

Analytics Cookies: These cookies collect information about how visitors interact with the Website, including traffic patterns and page popularity. They help us monitor performance and improve the user experience.

Targeting Cookies: Used by advertising partners, these cookies track your browsing activities to deliver advertisements relevant to your interests across other websites. These include cookies from social media platforms and third-party advertisers.

8.2 Managing Cookies:
You can manage cookies through your browser settings. Disabling some cookies may impact your experience on the Website.
9. Security of Your Data

9.1 Protection Measures:
We use industry-standard security measures to protect your personal data from unauthorized access, loss, or misuse. This includes encryption, firewalls, and access controls.

9.2 User Responsibility:
While we implement robust protections, you are responsible for maintaining the security of your devices and ensuring safe use of the Website.
10. Accuracy and Updates

10.1 The content on the Website is provided for informational purposes. While we strive for accuracy, we do not guarantee the completeness or timeliness of information.

10.2 We reserve the right to update, modify, or remove content without prior notice.
11. Contact Information

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at info@totemix.cy
12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Any updates will be posted on this page with the effective date. Continued use of the Website after such updates signifies acceptance of the changes.