MELIOR CAPITAL LTD, hereinafter “we”, “us”, “our” or “Ergodotisi” is a digital job classifieds platform operating in Cyprus. Its core function is to connect job seekers with employers through two primary mechanisms: job applications (eApply) and a searchable CV database (SEEK4U). Job seekers create accounts, upload CVs and apply to job posts. Employers register, create company profiles, publish job listings, and gain access to CVs through the CV Database if purchased (our ‘Services’).

This Privacy Policy describes how we collect and use your personal data, the purposes of processing, when we may disclose your personal data to third parties, as well as your rights in relation to it. We aim to process this personal data in full compliance with the General Regulation on the Protection of Personal Data of the European Union (Regulation 2016/679), hereafter referred to as "the Regulation", and the legislation in force in Cyprus, providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018), that govern the collection and processing of Personal Data of Individuals.

Please read our privacy practices carefully to understand our policies regarding your data and how we will treat them and do not hesitate to contact us with any questions.

“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

For the purposes of data protection legislation, our Company primarily acts as a Data Controller of your personal data. As a Data Controller, Ergodotisi processes personal data for the purposes presented in this Policy. In such situations the Company decides for the purposes and means of processing.

This Privacy Policy applies to Data we collect:

• When you contact us via telephone, social media, email, or our online chat.
• When you purchase our Services.
• When you register and create your account on Ergodotisi.
• Through the use of our platform and its features.
• When you provide us with your explicit consent.Through third parties in the standard course of the business we do in order to provide you
• with the service you requested.
• For the provision of customer and technical support.
• Through cookies, including third party cookies. Advertising providers, such as Google, use cookies to collect information about your activity on our platform. In combination with other information previously collected from you from other websites or apps etc, they will build or improve a profile about you, that will include your possible interests and personal aspects. Your profile can then be used to present advertising that appears more relevant based on your interests. For more information, please see our Cookie Banner.
   

We collect and use several types of data, in regard to the relationship we have with you. 
Such data might include:

For all platform users:

• Contact details, such as name, surname, phone number, email address, social media, and the contents of any communication.
• Data that we may collect through your use of our website, such as IP addresses, device/ browser details, accessed pages, referrer information and behavioural analytics.

For job seekers:

• Any information you submit when registering to our Platform, such as name and surname, email address, phone number (optional), city and country of residence.
• Any information contained in your user account and/or in the Online CV you can create with us, such as address, date of birth, LinkedIn page, personal website, education, previous experience, languages, skills, current and preferred salary (optional), categories of jobs you are seeking, your application history etc.
• Data contained in the CVs you choose to submit in the course of using our Services, such as work history, education, skills etc.

For employing company representatives:

• Any information you submit when registering to our Platform, such as name and surname, phone number, city and country, language of preference.
• Any information contained in your user account, including your job advertising history, payment history etc.
• Invoice data when you subscribe to or purchase certain paid Services.
   

In general, we might process your personal data for the following purposes:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). For more information regarding the balancing test we have carried out, please contact xx@digitaltree.com.cy.

We do not share your Personal Data with third parties except as indicated below:

• Affiliates: we share your Personal Data with our affiliates to the extent this is necessary for the purposes of providing billing, accounting, and marketing services (Digital Tree)
• Service Providers: We share your Personal Data with trusted third-party service providers, including:Developers (Kufar Tech)
  • Software, application service providers (Zoho)
  • Hosting and infrastructure providers (FocusNet, Vercel)
  • Email providers (Zoho)
  • Call center, telephony, and online chat providers (including call recording where applicable) (Cablenet/ Yeastar)
  • Marketing communication providers (Zoho)
  • Customer relationship management (CRM) and customer support providers (Zoho)
  • Payment solution providers (JCC)
  • Security, network protection, and application monitoring service providers (CloudFlare, Sentry)
• Third party sites for analytics and advertising (Google Ads, Google Analytics, Meta Pixel, TikTok, LinkedIn Pinterest) and for retargeting and audience creation (Meta).
• Employers: we share your Personal Data with employers who:
  • have subscribed to our Services in order to access our SEEK4U database, and view CVs uploaded by job seekers, and access the CVs of job seekers, and
  • who have posted job advertisements, for the purpose of managing application and recruitment.
• Official Authorities: we may share your Personal Data with courts, regulatory authorities, law enforcement agencies or other public bodies to comply with applicable laws and to protect our rights and interests. 

The Personal Data that we collect about you, including Personal Data, is stored and processed in Cyprus and/or in Countries within the European Union. Personal Data is transferred to third countries, for the purpose of providing you with our Services, as some of our Service Providers are located in and/or have access from countries outside the EU/EEA, including the United States, Belarus and India. 

Since our website allows cookies form third-party sites, which are deployed subject to your consent via our cookie banner, some Personal Data may be transferred outside the EU/EEA, including to countries such as the United States and China. For more information, please see our Cookie Banner.

Transfers take place only where appropriate safeguards are in place in accordance with the GDPR, in accordance with Article 46 of the GDPR, through the use of Standard Contractual Clauses (SCCs) and contractual confidentiality and data protection obligations. To obtain a copy of such safeguarding measures please contact our DPO at xx@digitaltree.com.cy.

The period for which we keep your Personal Data depends on the nature of our relationship with you and the purposes for which the data is processed. 

We keep your Personal Data for as long as you have an active relationship with us, as needed to provide you with our respective Services, and following that, as long as it is necessary for compliance with legal obligations, relevant laws of Cyprus, and to safeguard our rights and interests. 
Indicatively, if we have a contractual relationship with you, we will keep your personal data as long as this relationship persists, and following the end of this relationship or after a prolonged period of inactivity, we keep your Personal Data for a maximum of 6 years, in accordance with national laws and the statutory limitation periods for contractual claims. 

If we process your data based on your consent, we retain such data until you withdraw said consent, or following a prolonged period of inactivity, and for a maximum of 3 years after that. For the retention period of cookies please see our Cookie Banner.

We may keep your data for longer than the aforementioned periods if we cannot delete it for legal, regulatory or technical reasons, or in order to safeguard legitimate interests pursued by us or by a third party.  For example, we shall retain your payment data for a period of 7 years.
For further information regarding specific retention periods please contact our Data Protection Officer at xx@digitaltree.com.cy.

We take appropriate security technical and organisational measures (including physical, electronic and procedural measures) to safeguard your Personal Data from unauthorized access, unlawful use, intervention, modification or disclosure under the requirements of the Regulation. For example, only authorized employees are permitted to access Personal Data, and they may do so only for permitted business functions. In addition, we have trained our employees on how to handle, manage and process personal data, applied upgraded technical measures and transformed our policies and procedures in a way that will comply with the General Data Protection Regulation.

Additionally, for the purposes of protecting the integrity of our systems and information held within, we use appropriate technical measures such as HTTPS encryption across platform, password hashing, firewall and network security, anti-malware protection, business continuity measures, CDN protection etc. 

Services are not directed to individuals under 16 years of age (for Cyprus citizens is under 14). We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at the address listed below xx@digitaltree.com.cy.

We strive to provide you with choices regarding the Personal Data you provide to us. You can choose not to provide us with certain Personal Data, but that may result in you being unable to use certain Services.

If you provided Personal Data, you may terminate your relationship with us at any time as per the provision of the between us agreement or engagement. If you choose to do so, your Personal Data will be deleted in accordance with our retention policy.

We do not carry out automated decision making, including profiling, that produces legal or similarly significant effects on you within the meaning of Article 22 GDPR. 
However, we carry out limited profiling for marketing and communication purposes. This profiling involves the use of basic behavioral data, such as job search category or location, to segment users into mailing lists, allowing us to send you job alerts or newsletters relevant to you. 
This activity is based on your previously obtained explicit consent.

You have the right to object at any time to the processing of your personal data for such marketing purposes, which includes profiling, by submitting a written request to the email xx@digitaltree.com.cy.
 

Subject to the provisions of the GDPR, you have the following rights in regard to your Personal Data: (Please note, these rights are not absolute and in some cases, they are subjected to conditions as defined by law).

• Right to Withdraw your Consent- You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
  • Right of Access – You have the right to access your own Personal Data, as well as the right to request a copy of your personal data that is maintained and processed by our Company.
  • Right of Rectification - You have the right to request the correction of any incomplete and / or inaccurate Personal Data we hold for you.
  • Right to Erasure - You have the right to request the deletion of Personal Data only if one of the following reasons is true:
    • Personal Data are no longer necessary in relation to the purposes for which they were collected or processed.
      If the processing is based on your consent and you have withdrawn this consent (on which processing is based) in accordance with Articles 6.1.a and 9.2.a of the Regulation and if no other legal basis, for processing, applies.
    • If you object to processing in accordance with Article 21.1 of the Regulation and there are no compelling and legitimate reasons for processing.
    • If Personal Data have been processed illegally.
    • If Personal Data should be deleted in compliance with a legal obligation under Union law to which our Company is subject to.
    • If the personal data have been collected in relation to the provision of referred to in Article 8.1 of the Regulation.
  • Right to Object - You have the right to oppose the processing of your Personal Data at any time and for reasons related to a specific situation, unless there are compelling legitimate reasons for processing that override your interests, rights and freedoms.
  • Right to Restriction of Processing - You reserve the right to request the restriction of processing on your Personal Data so that we may no longer process the specific Data until the restriction is lifted (for example, the data have been corrected).
  • Right to Data Portability - You have the right to request the transfer of your personal data, that you have provided to our Company. These data will be given to you in a format that is structured, widely used and machine readable and, in certain cases you may also have the right to request for us to send the Data to another organization, provided that such a transfer is technically feasible.

If you have any questions in regard to the kind of Personal Data we hold for you, or if you want to exercise any of your Personal Data rights, please send a written request to the email xx@digitaltree.com.cy. However, we reserve the right to reject any requests for access or for imposing restrictions or other claims if required or permitted by the law.

We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version found at our website so you are aware of any changes, as they are binding on you.

If we change anything in our privacy policy, the date of change will be reflected in the “last modified date” below. You agree that you will periodically review this privacy policy and refresh the page when doing so. You agree to note the date of the last revision to our privacy policy. If the “last modified” date is unchanged from the last time you reviewed our privacy policy, then it is unchanged. On the other hand, if the date has changed, then there have been changes, and you agree to re-review our privacy policy, and you agree to the new ones. By continuing to use the Website, subsequent to us making available an amended version of our privacy policy in a way that you can easily take notice of it, you thereby consent to such amendment.

We do not guarantee error-free performance under this Privacy Policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our Privacy Policy. We shall not be liable for any incidental, consequential or punitive damages relating to this Privacy Policy.

If you have any questions about this privacy policy or our Data-handling practices, please contact us at

Email: xx@digitaltree.com.cy.
Tel: +357 22 285238

Submission of a Complaint:
If you feel that your concerns in regards to the use of your personal data or any of your data protection rights have not been addressed by us, you have the right to contact us at xx@digitaltree.com.cy and submit a complaint. 
You also have the right to submit a complaint with the Personal Data Protection Commissioner’s Office at http://www.dataprotection.gov.cy.

Last Modified date: December 2025