Privacy notice
This notice explains what personal data StartupAdil Ltd handles, why we handle it, and what you can ask us to do about it. It is short because we collect very little. This website sets no cookies, runs no analytics, and loads nothing from anyone else's servers.
Who we are
StartupAdil Ltd is the controller of the personal data described in this notice. We are a private limited company registered in the Republic of Cyprus under registration number HE 448588, with a registered office at 7 Theseos Street, ACFIN HOUSE, Strovolos, 2042 Nicosia (Lefkosia), Cyprus.
For anything to do with this notice or with your personal data, write to hello@startupadil.com.
We are not required to appoint a Data Protection Officer under Article 37 of the GDPR and have not appointed one. Privacy enquiries go to the address above and are handled by the company's management.
What this notice covers
It covers personal data we handle as a controller — that is, where we decide why and how it is processed. In practice that means visitors to startupadil.com, people who contact us, and the individuals we deal with at client, supplier and partner organisations.
It does not cover personal data we process on a client's behalf while building or running software for them. There the client is the controller, their own privacy notice applies, and our processing is governed by the data processing terms in our contract with them, as required by Article 28 of the GDPR.
What we collect
When you visit this website
The site sets no cookies, uses no analytics or advertising technology, and loads no scripts, fonts or images from third-party servers. Viewing it sends no data to anyone but us.
Our web hosting provider keeps standard server logs on our behalf: the requesting IP address, the date and time, the page or file requested, the response status, and the browser user-agent string. We use these to keep the site available, to diagnose faults, and to identify abuse.
When you contact us
The enquiry form on this site does not submit to a server. It assembles your message and opens it in your own email program — nothing reaches us unless you choose to press send. We therefore receive nothing at all from visitors who fill the form in and change their mind.
When you do email us, we receive your name, your email address, whatever company or role details you choose to give, the content of your message, and the routine technical headers that accompany any email.
If we work together
Where your organisation becomes a client, supplier or partner, we process business contact details for the individuals we deal with — name, job title, work email address and telephone number — together with correspondence and records of what was discussed and agreed.
We do not seek special category data, such as data about health, biometrics or political opinions, and we ask that you do not include any in an enquiry.
Why we process it, and on what basis
| What | Why | Legal basis |
|---|---|---|
| Enquiry correspondence | To answer you, and to work out whether we can help | Article 6(1)(b) — steps taken at your request before entering a contract; or Article 6(1)(f) — our legitimate interest in responding to business enquiries |
| Client, supplier and partner contact details and correspondence | To perform the contract and manage the working relationship | Article 6(1)(b) — performance of a contract; and Article 6(1)(f) — our legitimate interest in managing business relationships |
| Server logs | To keep the site available, secure and free from abuse | Article 6(1)(f) — our legitimate interest in the security and reliability of our systems |
| Invoices and accounting records | To meet our tax, accounting and company law obligations | Article 6(1)(c) — compliance with a legal obligation |
Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights and freedoms and concluded that it is not: the data involved is business contact information or routine technical data, it is used only for the purpose described, and it is never combined, profiled or sold. You can object to this processing at any time — see Your rights below.
We do not send marketing emails to people who have not asked to hear from us, and we do not buy contact lists.
Cookies
This site sets no cookies of any kind — not strictly necessary ones, not analytics ones, not advertising ones. There is no consent banner because there is nothing to consent to. If that ever changes, we will update this notice and ask for your consent where the law requires it.
Who we share it with
We do not sell, rent or trade personal data, and we do not use it for advertising or profiling. We share it only with:
- our web hosting provider and our email provider, who act as processors under written contracts meeting the requirements of Article 28 of the GDPR;
- our professional advisers — accountants, auditors and lawyers — where they need it in order to advise us;
- public authorities, courts or regulators, where we are legally required to disclose it.
We will tell you which processors we currently use if you ask.
Sending data outside the EEA
We prefer providers that keep data within the European Economic Area. Where a provider processes personal data outside the EEA, we rely on an adequacy decision of the European Commission covering that country, or on the European Commission's Standard Contractual Clauses together with any additional safeguards the transfer requires. We will provide a copy of the relevant safeguards on request.
How long we keep it
- Enquiries that do not lead to a working relationship — up to twelve months from our last exchange, then deleted.
- Client, supplier and partner records — for the duration of the relationship and six years afterwards, reflecting the record-keeping periods under Cyprus tax and company law and the limitation period for contractual claims.
- Server logs — retained by our hosting provider for a short rolling period, typically a matter of weeks, and then overwritten.
Where the law requires us to keep something for longer, we keep it for that longer period and for no other purpose.
How we protect it
The site is served over HTTPS. Access to correspondence and business records is limited to the people who need it to do their job, and we choose providers that maintain recognised security practices. We also keep the amount of personal data we hold deliberately small, which is the most reliable protection there is. No system is perfectly secure, but if a breach ever occurs we will notify you and the supervisory authority where the GDPR requires it.
Your rights
Under the GDPR you have the right to:
- Access — ask what personal data we hold about you, and get a copy of it.
- Rectification — have inaccurate or incomplete data corrected.
- Erasure — have data deleted where we no longer have grounds to keep it.
- Restriction — have us pause processing while a dispute is resolved.
- Objection — object to processing based on legitimate interests. If we ever process your data for direct marketing, you can object at any time and we must stop.
- Portability — receive data you gave us in a structured, commonly used, machine-readable format, or have it sent to another controller.
- Withdraw consent — where we rely on consent, which is rare, you can withdraw it at any time without affecting processing already carried out.
To exercise any of these, email hello@startupadil.com. We will respond within one month. If a request is complex, or you have made several, we may extend that by up to two further months, and we will tell you within the first month if we do. There is no charge unless a request is manifestly unfounded or excessive. We may ask you for enough information to satisfy ourselves of your identity before we act.
Automated decision-making
We do not make decisions about you by automated means, and we do not carry out profiling that produces legal effects concerning you or similarly significantly affects you.
Children
This is a business-to-business website. It is not directed at children, and we do not knowingly collect personal data relating to them.
Complaints
If something about the way we handle your data concerns you, please raise it with us first at hello@startupadil.com — it is usually the quickest way to put something right.
You also have the right to complain to a supervisory authority. Ours is the Office of the Commissioner for Personal Data Protection in Cyprus, dataprotection.gov.cy. You may instead complain to the supervisory authority in the EU or EEA country where you live or work, or where you believe the problem occurred.
Changes to this notice
We may update this notice as our practices or the law change. The date at the top of the page shows when it was last revised. Where a change materially affects how we use your personal data, we will take reasonable steps to bring it to your attention rather than relying on you to notice.