Privacy Policy — SAHR DIGITAL LTD
Last updated: 05 May 2025

This Privacy Policy (hereinafter – the “Policy”) defines the procedure for processing and protecting personal data provided by the User (a natural person) when using the website https://sahr.it.com (hereinafter – the “Website”).

The Policy is compiled in accordance with the General Data Protection Regulation (GDPR) and the Law of the Republic of Cyprus on Personal Data Protection (L.125(I)/2018).

1. Definitions and Key Terms
1.1 Personal Data – any information relating to an identified or identifiable natural person (User).
1.2 Processing – any operation or set of operations performed on personal data (collection, storage, transfer, deletion, etc.).
1.3 Operator – SAHR DIGITAL LTD responsible for the processing of personal data.
1.4 User – a natural person visiting the Website and providing their personal data.
1.5 Form – a web form on the Website through which the User submits a request.
1.6 Cookies – small fragments of data stored on the User’s device for identification and behaviour analysis
1.7 Anonymization – data processing so that identity cannot be determined without additional information.

2. General Provisions
2.1 This Policy applies only to the Website https://sahr.it.com.
2.2 The Operator ensures protection of personal data during collection, storage and processing.
2.3 Use of the Website and submission of data via Forms constitute acceptance of this Policy.
2.4 If the User disagrees with the Policy, they must cease using the Website.
2.5 The Operator may amend the Policy; the current version date is indicated at the top.

3. User Consent to Personal Data Processing
3.1 By filling out Forms and ticking the checkbox, the User:
— confirms familiarity with this Policy;
— gives voluntary, specific, informed and unambiguous consent;
— confirms that the data is accurate and belongs to them.
3.2 The User may withdraw consent at any time by emailing info@sahr.digital.
Withdrawal does not affect the lawfulness of processing before withdrawal.

4. Legal Grounds for Personal Data Processing
Processing is carried out on the basis of:
— User consent (Section 3);
— necessity for the performance of a contract or steps at the User’s request prior to entering into a contract;
— legitimate interests of the Operator (e.g., analytics, security);
— legal obligations under Cyprus and EU law.

5. Categories of Personal Data Processed
5.1 We process the following data:
— first and last name;
— email address;
— phone number;
— job title and/or company name (if provided);
— language preference;
— amoCRM ID (where applicable);
— IP address, browser/device type, referrer, visit time, on-site actions.
5.2 Data is provided via Forms or collected automatically using cookies and analytics tools.

6. Purpose of Personal Data Processing
— responding to inquiries and feedback;
— performance of contracts or preparation of offers;
— improving the Website and its functionality;
— analytics and marketing based on legitimate interest;
— behaviour analysis (via Google Analytics);
— compliance with legal requirements;
— fraud prevention and security.

7. Cookies and Analytics
7.1 The Website uses cookies for session management, preference storage and behaviour analysis.
7.2 The User may disable cookies in their browser settings.
7.3 The Website uses Google Analytics.
More: https://policies.google.com/privacy

8. Data Retention and Transfer to Third Parties
8.1 Data is stored as long as necessary for the purposes set out in Section 6.
8.2 Data may be transferred to:
— amoCRM (for request processing);
— Google Analytics (for statistical analysis).
8.3 All transfers comply with GDPR using Standard Contractual Clauses (SCC) or equivalent safeguards.
9. Security MeasuresThe Operator applies technical and organisational measures to protect personal data from:
— unauthorised access;
— loss, destruction or alteration;
— unlawful disclosure and other risks.
Access is granted only to employees and contractors who need it.

10. User RightsUnder GDPR, the User has the right to:
— access their data;
— rectify or delete data;
— restrict processing;
— data portability;
— withdraw consent;
— lodge a complaint with the Cyprus supervisory authority:
https://www.dataprotection.gov.cy

11. Operator Contact Details
Operator: SAHR DIGITAL LTD
Email: info@sahr.digital
Address: 11 Pyrogiou, 2201, Geri, Nicosia, Cyprus