Privacy Policy

1. Introduction

Novyqra Ltd ("we", "our", or "us") is committed to protecting your privacy and personal data. This privacy policy explains how we collect, use, process, and safeguard your information when you visit our website or use our financial independence services. We are the data controller for the personal information we process about you.

2. Data We Collect

The data we collect includes information you provide directly to us and information we gather automatically when you interact with our services. Personal data collection occurs through various touchpoints including our website, consultation forms, and direct communications.

2.1 Information You Provide

• Contact details (name, email address, phone number, postal address)
• Financial information relevant to our advisory services
• Communication preferences and consultation requests
• Feedback and correspondence with our team
• Professional and employment information

2.2 Information We Collect Automatically

• Website usage data and analytics information
• IP address, browser type, and device information
• Cookies and similar tracking technologies
• Pages visited and time spent on our website

3. How We Use Your Information

We use of your data is governed by legitimate business interests and your consent where required. The primary purpose is to provide you with exceptional financial independence advisory services and maintain ongoing client relationships.

3.1 Service Provision

• Providing financial independence advisory services
• Conducting consultations and assessments
• Developing personalised financial strategies
• Communicating about our services and your account

3.2 Business Operations

• Processing payments and managing accounts
• Improving our services and website functionality
• Compliance with legal and regulatory requirements
• Fraud prevention and security measures

4. Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use and how to control them, please see our Cookie Policy.

5. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Consent: Where you have given clear consent for specific processing activities
• Contract: To perform our contractual obligations in providing services
• Legitimate interests: For business operations and service improvement
• Legal obligation: To comply with applicable laws and regulations

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with trusted third parties only in the following circumstances:

• Service providers who assist in delivering our services
• Professional advisors (lawyers, accountants, auditors)
• Regulatory bodies when required by law
• In connection with business transfers or mergers

7. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes outlined in this policy and comply with our legal obligations. Generally, we keep client data for seven years after the end of our business relationship, unless a longer retention period is required by law. Data retention periods may vary based on the type of information and legal requirements applicable to our business.

8. International Data Transfers

As we operate within the European Union, your data is primarily processed within the EU. If we transfer data outside the EU, we ensure appropriate safeguards are in place, including adequacy decisions or standard contractual clauses approved by the European Commission.

9. Your Rights

Under GDPR and applicable data protection laws, you have the following rights regarding your personal data:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data in certain circumstances
• Restriction: Limit how we process your data
• Portability: Receive your data in a structured format
• Objection: Object to certain types of processing
• Withdraw consent: Where processing is based on consent

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training on data protection principles.

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal data, please contact us immediately.

12. Changes to This Policy

We may update this privacy policy periodically to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "last updated" date.

13. Contact Information

If you have questions about this privacy policy or wish to exercise your data protection rights, please contact us using the details below:

14. Supervisory Authority

If you believe we have not handled your personal data in accordance with this policy or applicable law, you have the right to lodge a complaint with the relevant supervisory authority. In Cyprus, this is the Office of the Commissioner for Personal Data Protection.