1. Who we are
This website and related services are operated by Spelione Limited, trading as eyetouch (“we”, “us”, or the “Company”). We act as the data controller for personal data processed through this site when we determine the purposes and means of processing, unless stated otherwise (for example where we process data solely on behalf of a business customer under a data processing agreement).
Registered office / principal place of business: Georgiou Griva Digeni 42, Nicosia 1096, Cyprus. For privacy-related requests, please use our contact page or the details published there.
2. Scope of this policy
This policy describes how we collect, use, store, and protect personal data when you visit our public website, request information, purchase or enquire about products and services, use partner or dealer portals where we operate them, or otherwise interact with us online. It is intended to meet our transparency obligations under the EU General Data Protection Regulation (“GDPR”) and applicable Cyprus law.
Separate notices or agreements may apply to specific programmes (for example authorised dealers, visitors, or enterprise contracts). Where those documents conflict on a specific point, the programme-specific terms prevail for that programme.
3. Data we may collect
Depending on how you interact with us, we may process categories such as:
- 1Identity & contact: name, email address, phone number, company name, job title, and similar details you provide via forms, email, chat, or phone.
- 2Transaction & account: order history, delivery or installation addresses, billing references, and support or warranty correspondence.
- 3Technical & usage: IP address, browser type, device identifiers, approximate location derived from IP, pages viewed, referring URLs, and timestamps — often collected via cookies or similar technologies (see below).
- 4Communications: content of messages you send us, feedback, and records needed to handle complaints or legal claims.
- 5Special categories: we do not ask for health or other special-category data through this website. If you voluntarily send us such information, we will only use it where we have a valid legal basis and it is strictly necessary.
4. How and why we use your data
We process personal data for purposes such as:
- Providing our website and improving its security, performance, and usability.
- Responding to enquiries, quotes, and support requests.
- Fulfilling contracts — including sales, delivery, installation, warranty, and after-sales service.
- Compliance with legal obligations (for example tax, accounting, or court orders).
- Legitimate interests where balanced against your rights — for example fraud prevention, network security, aggregated analytics, and direct marketing to business contacts where permitted and with appropriate opt-outs where required.
Where we rely on consent (for example certain cookies or marketing emails), you may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
5. Legal bases (GDPR)
We rely on one or more of the following legal bases, as appropriate:
- 1Contract — processing necessary to perform a contract with you or to take steps at your request before entering a contract.
- 2Legal obligation — where EU or Cyprus law requires us to process data.
- 3Legitimate interests — for example operating our business, securing systems, and improving products and services, except where overridden by your interests or fundamental rights.
- 4Consent — where we ask for it explicitly.
8. International transfers
Where we transfer personal data outside the European Economic Area, we will ensure appropriate safeguards (such as Standard Contractual Clauses approved by the European Commission or adequacy decisions), unless a derogation applies.
9. Retention
We keep personal data only as long as necessary for the purposes described, including to satisfy legal, accounting, or reporting requirements. Retention periods vary by data type and context; for example, contract and invoice data may be retained longer than transient server logs.
10. Security
We implement appropriate technical and organisational measures designed to protect personal data against accidental loss, unauthorised access, alteration, or disclosure. No method of transmission over the Internet is completely secure; we encourage you to use strong passwords and protect your credentials.
11. Your rights
Subject to applicable law, you may have the right to:
- Access the personal data we hold about you.
- Rectify inaccurate data or complete incomplete data.
- Erase data in certain circumstances (“right to be forgotten”).
- Restrict processing in certain circumstances.
- Data portability for data you provided where processing is based on consent or contract and automated.
- Object to processing based on legitimate interests or for direct marketing.
- Withdraw consent where processing is consent-based.
- Lodge a complaint with a supervisory authority — in Cyprus, the Office of the Commissioner for Personal Data Protection.
To exercise these rights, contact us using the details on our contact page. We may need to verify your identity before responding.
12. Children
Our services are not directed at children under 16. We do not knowingly collect personal data from children. If you believe we have collected such data, please contact us and we will take steps to delete it where appropriate.
13. Third-party websites
Our site may contain links to third-party websites or integrations. This policy does not apply to those services; please review their privacy notices before providing personal data.
14. Changes to this policy
We may update this policy from time to time. The “Last updated” indicator on the privacy page (or equivalent notice) will reflect material changes where required. Continued use of the site after changes may constitute acceptance where permitted by law.
15. Contact
For privacy questions or requests, please reach out through our contact channels. We aim to respond within a reasonable period and within statutory deadlines where the GDPR applies.
This policy is a general transparency notice. For specific agreements (dealers, enterprise customers), see your contract or separate privacy documentation. Questions? Contact us.