Last updated: June 2026
These Terms of Use (“Terms”) govern your access to and use of the website spm.family (the “Website”), operated by S. Polivar Management LTD, trading as SPM Family Office (“SPM”, “we”, “us”). By accessing or using the Website, you agree to be bound by these Terms. If you do not agree, please do not use the Website.
The Website is intended for adults seeking information about our advisory services. By using it, you confirm that you are at least 18 years old and legally able to enter into these Terms.
The Website is provided for general informational purposes only. Nothing on the Website constitutes, or should be relied upon as, legal, tax, financial, investment or other professional advice. You should obtain professional advice tailored to your specific circumstances before taking, or refraining from, any action.
Accessing the Website or submitting an enquiry does not create a client, advisory or fiduciary relationship with SPM. A formal engagement arises only upon the execution of a written engagement letter signed by both parties. Information you submit through the Website is treated in accordance with our Privacy Policy, but submitting it does not oblige us to provide services.
You may use the Website for lawful, personal and business-informational purposes, in accordance with these Terms and all applicable laws.
You agree not to:
All content on the Website — including text, design, layout, graphics, logos and structure — is owned by S. Polivar Management LTD or its licensors and is protected by intellectual property laws. Except as expressly permitted, you may not reproduce, distribute, modify, publish or use any content without our prior written consent. All rights not expressly granted are reserved.
You are responsible for ensuring that any information you submit through the Website is accurate and that you are entitled to provide it. You should not submit confidential or sensitive information through the enquiry form beyond what is necessary to describe your initial request.
We make reasonable efforts to ensure the Website is accurate and available, but we do not warrant that it will be uninterrupted, error-free, or that defects will be corrected. Laws, regulations and market conditions change, and content may become out of date. We may modify, suspend or discontinue any part of the Website at any time without notice.
The Website may contain links to third-party websites. We are not responsible for the content, accuracy or practices of any third-party website, and the inclusion of any link does not imply endorsement.
To the fullest extent permitted by applicable law, the Website and its content are provided “as is” and “as available”, without warranties of any kind, whether express or implied, including warranties of accuracy, merchantability, fitness for a particular purpose, or non-infringement.
To the fullest extent permitted by applicable law, SPM and S. Polivar Management LTD shall not be liable for any direct, indirect, incidental, special, consequential or punitive damages, or any loss of profits, data, goodwill or other intangible losses, arising out of or in connection with your use of, or inability to use, the Website or its content. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law.
You agree to indemnify and hold harmless SPM and S. Polivar Management LTD, and their directors and personnel, from any claims, losses or expenses arising out of your breach of these Terms or your unlawful use of the Website.
Your use of the Website is also governed by our Privacy Policy and Cookie Policy, which are incorporated into these Terms by reference.
We may update these Terms from time to time. The “Last updated” date indicates the current version. Your continued use of the Website after changes take effect constitutes acceptance of the revised Terms.
If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will continue in full force and effect. Our failure to enforce any provision is not a waiver of our right to do so later.
These Terms, together with the Privacy Policy, Cookie Policy, Legal Notice and Disclosures, constitute the entire agreement between you and us regarding your use of the Website.
These Terms are governed by the laws of the Republic of Cyprus. Any disputes arising out of or in connection with these Terms or the Website shall be subject to the exclusive jurisdiction of the courts of Cyprus, without prejudice to any mandatory consumer-protection rights you may have in your country of residence.
Questions about these Terms may be sent to [email protected], or to S. Polivar Management LTD at the address above.
Get in touch
Every engagement begins with a focused assessment. We respond within two business days.
We respond to all qualified enquiries within two business days.
This website (spm.family) is provided and operated by:
Polivar Management LTD (trading as SPM Family Office) Marimax Business Center, Dimokratias Ave 44, Office 104/1st Floor, Paphos 8028, Cyprus Company registration number: HE368516 VAT number: CY10368516R Director / authorised representative: Serhii Polivar Email: [email protected]
S. Polivar Management LTD is responsible for the content published on this website. We prepare content with reasonable care; however, see the disclaimers below and our Terms of Use and Disclosures pages.
SPM Family Office is an independent advisory and structuring practice. It is not a bank, licensed investment manager, law firm or insurance provider, and does not provide regulated financial services. The full regulatory statement is set out on our Disclosures page.
The information on this website is provided for general information only and is subject to change. We do not warrant that the content is complete, accurate or up to date, and it does not constitute legal, tax, financial or investment advice.
This website may contain links to external websites operated by third parties. We have no control over, and accept no responsibility for, the content, accuracy or availability of such external sites. The inclusion of any link does not imply endorsement.
All content on this website — including text, design, layout, graphics and logos — is the property of S. Polivar Management LTD or its licensors and is protected by applicable intellectual property laws. It may not be reproduced, distributed or otherwise used without our prior written consent.
The European Commission provides a platform for online dispute resolution (ODR) at ec.europa.eu/consumers/odr. We are not obliged, and do not undertake, to participate in dispute-resolution proceedings before a consumer arbitration board.
This Legal Notice and the use of this website are governed by the laws of the Republic of Cyprus, as further set out in our Terms of Use.
This Cookie Policy explains how S. Polivar Management LTD (trading as SPM Family Office) uses cookies and similar technologies on spm.family, what categories we use, and how you can control them. It should be read together with our Privacy Policy, which explains how we handle the personal data collected through these technologies.
Cookies are small text files placed on your device when you visit a website. They allow the site to recognise your device, remember your choices, and — where you consent — measure usage and support advertising.
We also use technologies that work in a similar way, collectively referred to as “cookies” in this Policy:
Cookies can be distinguished by duration — session cookies (deleted when you close your browser) and persistent cookies (remaining until they expire or are deleted) — and by origin — first-party cookies (set by spm.family) and third-party cookies (set by our service providers, such as Google and Microsoft).
We use cookies to: (a) make the Website function and remain secure; (b) remember your preferences; (c) understand how visitors use the Website so we can improve it; and (d) measure and optimise our advertising.
In accordance with the ePrivacy Directive and the GDPR, strictly necessary cookies are set without consent because they are essential for the Website to operate. All other cookies — preferences, statistics/analytics and marketing — are set only on the basis of your prior consent (Article 6(1)(a) GDPR).
When you first visit the Website, our consent banner — provided by Cookiebot — asks you to choose which categories you allow. We use Google Consent Mode in Google Tag Manager, so analytics and advertising tags do not collect or transmit data until the relevant consent has been given. You can change or withdraw your consent at any time (see Section 7).
Strictly necessary — required for the Website to function (security, load balancing, and storing your cookie-consent choices). These do not require consent.
Preferences — remember choices you make (such as language) to provide enhanced, personalised features.
Statistics / Analytics — help us understand how visitors interact with the Website, on an aggregated basis, so we can improve it. Set only with your consent.
Marketing / Advertising — used to measure the effectiveness of, and to deliver and optimise, our advertising; and, where applicable, to build audiences. Set only with your consent.
The tables below describe the principal cookies used on the Website. The authoritative, automatically updated list — including any cookies not shown here — is generated by Cookiebot and displayed via the Cookie Declaration (see Section 9). Durations are indicative and may vary by provider configuration.
6.1 Strictly necessary
Cookie
Provider
Purpose
Duration
CookieConsent
Cookiebot (spm.family)
Stores your cookie-consent state for the current domain
1 year
6.2 Statistics / Analytics (set only after consent)
Cookie
Provider
Purpose
Duration
_ga
Google Analytics 4
Distinguishes unique users
~2 years
_ga_<container-id>
Google Analytics 4
Persists session state for GA4
~2 years
_gid
Google Analytics
Distinguishes users
24 hours
_gat / _gat_*
Google Analytics
Throttles request rate
1 minute
_clck
Microsoft Clarity
Persists the Clarity user ID and preferences
1 year
_clsk
Microsoft Clarity
Connects multiple page views into a single session recording
1 day
CLID
Microsoft Clarity
Identifies the first time Clarity saw this user on the site
1 year
ANONCHK
Microsoft (Clarity/Bing)
Indicates whether the MUID identifier is used for analytics
10 minutes
MR
Microsoft (Clarity/Bing)
Indicates whether to refresh the MUID identifier
7 days
MUID
Microsoft (Clarity/Bing)
Identifies unique browsers for analytics and operational purposes
~1 year
SM
Microsoft (Clarity)
Synchronises the MUID identifier across Microsoft domains
Session
Cookie
Provider
_ga
Google Analytics 4
_ga_<container-id>
Google Analytics 4
_gid
Google Analytics
_gat / _gat_*
Google Analytics
_clck
Microsoft Clarity
_clsk
Microsoft Clarity
CLID
Microsoft Clarity
ANONCHK
Microsoft (Clarity/Bing)
MR
Microsoft (Clarity/Bing)
MUID
Microsoft (Clarity/Bing)
SM
Microsoft (Clarity)
Purpose
Duration
Distinguishes unique users
~2 years
Persists session state for GA4
~2 years
Distinguishes users
24 hours
Throttles request rate
1 minute
Persists the Clarity user ID and preferences
1 year
Connects multiple page views into a single session recording
1 day
Identifies the first time Clarity saw this user on the site
1 year
Indicates whether the MUID identifier is used for analytics
10 minutes
Indicates whether to refresh the MUID identifier
7 days
Identifies unique browsers for analytics and operational purposes
~1 year
Synchronises the MUID identifier across Microsoft domains
Session
Microsoft Clarity also provides heatmaps and session recordings (clicks, scrolling and mouse movement). Clarity applies automatic masking to input fields; we do not use it to capture the content you type into forms.
6.3 Marketing / Advertising (set only after consent)
Cookie
Provider
Purpose
Duration
_gcl_au
Google Ads (Conversion Linker)
Stores and tracks ad-click conversions
3 months
IDE
Google (doubleclick.net)
Measures and reports on ad performance; remarketing
~1 year
test_cookie
Google (doubleclick.net)
Checks whether the browser supports cookies
1 day
_gcl_*
(variants)
Google Ads
Conversion attribution
Up to 3 months
Cookie
Provider
_gcl_au
Google Ads (Conversion Linker)
IDE
Google (doubleclick.net)
test_cookie
Google (doubleclick.net)
_gcl_*
(variants)
Google Ads
Purpose
Duration
Stores and tracks ad-click conversions
3 months
Measures and reports on ad performance; remarketing
~1 year
Checks whether the browser supports cookies
1 day
Conversion attribution
Up to 3 months
Some browsers offer “Do Not Track” (DNT) or Global Privacy Control (GPC) signals. As there is currently no uniform industry standard for how these signals must be handled, our primary mechanism for honouring your choices is the Cookiebot consent banner described above.
To keep the cookie list accurate and in sync with each scan, embed the Cookiebot Cookie Declaration on this page:
<script id="CookieDeclaration"
src="https://consent.cookiebot.com/{YOUR-CBID}/cd.js"
type="text/javascript" async></script>
For details of how our providers process data, see: Google Privacy Policy — policies.google.com/privacy; Microsoft Privacy Statement — privacy.microsoft.com; Cookiebot/Usercentrics — usercentrics.com.
If you decline non-essential cookies, the Website will continue to function, but some features may be limited and we will be unable to measure and improve your experience or the effectiveness of our communications.
We may update this Cookie Policy from time to time; the “Last updated” date reflects the current version. Questions can be sent to [email protected].
SPM Family Office provides independent advisory and structuring services to private clients, families and entrepreneurs operating across multiple jurisdictions. Our practice focuses on cross-border residency planning, asset structuring, corporate organisation and investment advisory. All services are provided pursuant to a written engagement letter that defines the scope, terms and limitations of our work.
SPM Family Office is an independent advisory practice. We are not a bank, licensed investment firm, asset manager, law firm or insurance provider. We do not hold or manage client funds, and we do not provide regulated financial services as defined under MiFID II or equivalent legislation. Where regulated services are required, we coordinate with, and introduce clients to, appropriately licensed professionals in the relevant jurisdiction.
Nothing on this website, or in any general communication from SPM, constitutes investment advice, a recommendation, an offer, or a solicitation to buy or sell any financial instrument or to enter into any transaction. Any references to structures, jurisdictions or approaches are illustrative and general in nature, and do not take account of your individual circumstances.
SPM operates on a fee-for-service basis. We do not receive commissions, referral fees or undisclosed compensation from third-party service providers. All referrals to external counsel, banks or corporate service providers are made solely on the basis of professional judgement and the client’s interest.
Our advisory services operate across Cyprus, Liechtenstein and Switzerland. Advice on legal and tax matters in these jurisdictions is provided in coordination with locally licensed legal and tax professionals. We do not hold ourselves out as providing jurisdiction-specific legal or tax advice independently of such professionals.
All structuring and planning work is based on the law, regulation and administrative practice in force at the time of engagement. Laws and their interpretation change, and no guarantee is made as to the future treatment of any structure, residency status or tax position. Past results achieved for other clients are not indicative of future outcomes.
Any forward-looking statements, projections or expectations referenced in our materials are inherently uncertain and subject to change. They should not be relied upon as a promise or guarantee of any future result.
Where we accept an engagement, we are required to perform client due diligence and to comply with applicable anti-money-laundering (“AML”) and counter-terrorist-financing obligations. We may be required to obtain and verify identity and source-of-funds information before or during an engagement.
We maintain a formal conflict-of-interest policy. Where a potential conflict is identified, it is disclosed to the client before the engagement proceeds. Clients retain the right to seek independent advice at any stage.
We treat all client information as strictly confidential and disclose it only as necessary to provide the services requested, or where required by law or regulation, in accordance with our Privacy Policy and applicable professional obligations.
For questions about these disclosures, please contact [email protected].
These Terms of Use (“Terms”) govern your access to and use of the website spm.family (the “Website”), operated by S. Polivar Management LTD, trading as SPM Family Office (“SPM”, “we”, “us”). By accessing or using the Website, you agree to be bound by these Terms. If you do not agree, please do not use the Website.
S. Polivar Management LTD is a company incorporated in the Republic of Cyprus (registration number HE368516; VAT CY10368516R), with its registered office at Marimax Business Center, Dimokratias Ave 44, Office 104/1st Floor, Paphos 8028, Cyprus.
The Website is intended for adults seeking information about our advisory services. By using it, you confirm that you are at least 18 years old and legally able to enter into these Terms.
The Website is provided for general informational purposes only. Nothing on the Website constitutes, or should be relied upon as, legal, tax, financial, investment or other professional advice. You should obtain professional advice tailored to your specific circumstances before taking, or refraining from, any action.
Accessing the Website or submitting an enquiry does not create a client, advisory or fiduciary relationship with SPM. A formal engagement arises only upon the execution of a written engagement letter signed by both parties. Information you submit through the Website is treated in accordance with our Privacy Policy, but submitting it does not oblige us to provide services.
You may use the Website for lawful, personal and business-informational purposes, in accordance with these Terms and all applicable laws.
You agree not to:
All content on the Website — including text, design, layout, graphics, logos and structure — is owned by S. Polivar Management LTD or its licensors and is protected by intellectual property laws. Except as expressly permitted, you may not reproduce, distribute, modify, publish or use any content without our prior written consent. All rights not expressly granted are reserved.
You are responsible for ensuring that any information you submit through the Website is accurate and that you are entitled to provide it. You should not submit confidential or sensitive information through the enquiry form beyond what is necessary to describe your initial request.
We make reasonable efforts to ensure the Website is accurate and available, but we do not warrant that it will be uninterrupted, error-free, or that defects will be corrected. Laws, regulations and market conditions change, and content may become out of date. We may modify, suspend or discontinue any part of the Website at any time without notice.
The Website may contain links to third-party websites. We are not responsible for the content, accuracy or practices of any third-party website, and the inclusion of any link does not imply endorsement.
To the fullest extent permitted by applicable law, the Website and its content are provided “as is” and “as available”, without warranties of any kind, whether express or implied, including warranties of accuracy, merchantability, fitness for a particular purpose, or non-infringement.
To the fullest extent permitted by applicable law, SPM and S. Polivar Management LTD shall not be liable for any direct, indirect, incidental, special, consequential or punitive damages, or any loss of profits, data, goodwill or other intangible losses, arising out of or in connection with your use of, or inability to use, the Website or its content. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law.
You agree to indemnify and hold harmless SPM and S. Polivar Management LTD, and their directors and personnel, from any claims, losses or expenses arising out of your breach of these Terms or your unlawful use of the Website.
Your use of the Website is also governed by our Privacy Policy and Cookie Policy, which are incorporated into these Terms by reference.
We may update these Terms from time to time. The “Last updated” date indicates the current version. Your continued use of the Website after changes take effect constitutes acceptance of the revised Terms.
If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will continue in full force and effect. Our failure to enforce any provision is not a waiver of our right to do so later.
These Terms, together with the Privacy Policy, Cookie Policy, Legal Notice and Disclosures, constitute the entire agreement between you and us regarding your use of the Website.
These Terms are governed by the laws of the Republic of Cyprus. Any disputes arising out of or in connection with these Terms or the Website shall be subject to the exclusive jurisdiction of the courts of Cyprus, without prejudice to any mandatory consumer-protection rights you may have in your country of residence.
Questions about these Terms may be sent to [email protected], or to S. Polivar Management LTD at the address above.
This Privacy Policy explains how S. Polivar Management LTD, trading as SPM Family Office ("SPM", "we", "us", "our"), collects, uses, discloses and protects personal data when you visit spm.family (the "Website"), submit an enquiry, or otherwise interact with us through this Website.
We take the protection of your personal data seriously. This Policy is intended to give you a clear and complete picture of our data practices, in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and applicable national law. Where you are located in Switzerland, your equivalent rights under the Swiss Federal Act on Data Protection (FADP) are also respected.
Please read this Policy together with our Cookie Policy, which forms part of it and describes in detail the cookies and tracking technologies used on the Website.
The data controller responsible for the processing of your personal data is:
S. Polivar Management LTD (trading as SPM Family Office) Marimax Business Center, Dimokratias Ave 44, Office 104/1st Floor, Paphos 8028, Cyprus Company registration number: HE368516 VAT number: CY10368516R Director: Serhii Polivar Email for data protection matters: [email protected]
SPM is a cross-border advisory and structuring practice operating across Cyprus, Liechtenstein and Switzerland. As the controller is established in the European Union, the GDPR is the primary framework governing this Policy.
For clarity, certain terms used in this Policy have the meaning given in the GDPR, including: "personal data" (any information relating to an identified or identifiable natural person); "processing" (any operation performed on personal data); "controller" (the party determining the purposes and means of processing); "processor" (a party processing data on behalf of the controller); and "data subject" (the individual to whom the personal data relates — i.e. you).
We collect personal data in the following ways.
4.1 Data you provide to us directly. When you complete the consultation enquiry form, send us an email, or otherwise communicate with us, we collect:
We ask that you do not include unnecessary sensitive information in free-text fields. We do not seek to collect special categories of data (such as data revealing health, political opinions, or religious beliefs) through the Website.
4.2 Data collected automatically. Subject to your consent where required (see Section 6 and our Cookie Policy), we and our service providers collect:
4.3 Server logs. Our hosting infrastructure automatically records standard technical information (such as IP address, timestamp, requested resource and HTTP status) for security, troubleshooting and integrity purposes.
We process personal data only where we have a lawful basis to do so under Article 6 GDPR. The table below sets out each purpose and its corresponding legal basis.
#
Purpose
Categories of data
Legal basis (Art. 6 GDPR)
a
To receive and respond to your enquiry, and to assess whether and how we can assist you
Identity, contact, enquiry content
Steps taken at your request prior to a possible engagement — Art. 6(1)(b); and/or our legitimate interest in responding to enquiries — Art. 6(1)(f)
b
To communicate with you regarding your enquiry or a prospective engagement
Identity, contact, enquiry content
Art. 6(1)(b) and/or Art. 6(1)(f)
c
To measure and improve the performance, content and usability of the Website (analytics and session analysis)
Technical, usage, session/usability
Your consent — Art. 6(1)(a)
d
To operate and measure our advertising, including campaign performance and audience building
Technical, usage, conversion
Your consent — Art. 6(1)(a)
e
To maintain the security, availability and integrity of the Website and to prevent abuse
Technical, server logs
Our legitimate interest — Art. 6(1)(f)
f
To comply with legal, regulatory and professional obligations, and to establish, exercise or defend legal claims
As relevant
Legal obligation — Art. 6(1)(c); and/or legitimate interest — Art. 6(1)(f)
#
Purpose
a
To receive and respond to your enquiry, and to assess whether and how we can assist you
b
To communicate with you regarding your enquiry or a prospective engagement
c
To measure and improve the performance, content and usability of the Website (analytics and session analysis)
d
To operate and measure our advertising, including campaign performance and audience building
e
To maintain the security, availability and integrity of the Website and to prevent abuse
f
To comply with legal, regulatory and professional obligations, and to establish, exercise or defend legal claims
#
Categories of data
a
Identity, contact, enquiry content
b
Identity, contact, enquiry content
c
Technical, usage, session/usability
d
Technical, usage, conversion
e
Technical, server logs
f
As relevant
#
Legal basis (Art. 6 GDPR)
a
Steps taken at your request prior to a possible engagement — Art. 6(1)(b); and/or our legitimate interest in responding to enquiries — Art. 6(1)(f)
b
Art. 6(1)(b) and/or Art. 6(1)(f)
c
Your consent — Art. 6(1)(a)
d
Your consent — Art. 6(1)(a)
e
Our legitimate interest — Art. 6(1)(f)
f
Legal obligation — Art. 6(1)(c); and/or legitimate interest — Art. 6(1)(f)
Where our basis is legitimate interest, we have balanced that interest against your rights and freedoms; you may object to such processing as described in Section 11.
The Website uses cookies and similar technologies. Strictly necessary cookies are essential for the Website to function and are set without consent. All non-essential cookies — including analytics (Google Analytics 4, Microsoft Clarity) and advertising (Google Ads) — are set only after you give consent via our consent banner, which is operated by Cookiebot. You may grant, refuse, or withdraw consent at any time, without detriment.
We deploy our tags through Google Tag Manager, configured with Google Consent Mode, so that analytics and advertising tags do not collect or transmit data until the corresponding consent has been granted.
A full description of each category, the specific tools, and the individual cookies (with their purposes and durations) is set out in our Cookie Policy.
We do not use enquiry data to send unsolicited marketing. If, in the future, we offer the option to subscribe to updates, we will only send such communications on the basis of your consent, and every message will include an option to unsubscribe.
We disclose personal data only where necessary and subject to appropriate safeguards. The categories of recipients are:
8.1 Professional advisors and counsel. Where required to provide services you have requested, we may share information with legal, tax and other professional advisors in the relevant jurisdictions. All such parties are bound by strict confidentiality and, where applicable, professional secrecy obligations.
8.2 Technology service providers (processors) acting on our behalf and under data processing agreements:
8.3 Public authorities and other third parties where disclosure is required by law, regulation, court order, or to protect our legal rights.
We do not sell personal data, and we do not share it with third parties for their own independent marketing or commercial purposes.
Some of our service providers (notably Google and Microsoft) are established in, or process data in, the United States. Where personal data is transferred outside the European Economic Area (EEA), we ensure an appropriate transfer mechanism under Chapter V GDPR is in place, namely:
You may request a copy of, or further information about, the relevant safeguards by contacting us at [email protected]. For Swiss-originating data, equivalent mechanisms under the Swiss FADP (including the Swiss–U.S. Data Privacy Framework and the Swiss addendum to the SCCs) apply.
We keep personal data only for as long as necessary for the purposes for which it was collected, after which it is securely deleted or anonymised.
Data
Retention period
Enquiry and contact data (no engagement established)
24 months from your last contact, then securely deleted
Engagement / client data
For the duration of the engagement and thereafter for statutory and professional retention periods applicable in the relevant jurisdiction
Analytics data (GA4, Microsoft Clarity)
For the retention periods configured in each tool and the lifetimes of the relevant cookies (see Cookie Policy)
Advertising data (Google Ads)
For the lifetimes of the relevant cookies and the periods configured in the platform
Server logs
Only as long as necessary for security and integrity purposes
Under the GDPR (and, for Swiss residents, the FADP), you have the following rights in respect of your personal data:
How to exercise your rights. Please contact us at [email protected]. We may need to verify your identity before responding. We will respond without undue delay and in any event within one month of receipt, which may be extended by a further two months for complex or numerous requests (we will inform you if so). Exercising your rights is free of charge, save where requests are manifestly unfounded or excessive.
Right to complain. Without prejudice to any other remedy, you may lodge a complaint with a supervisory authority, in particular in the EEA Member State of your residence, place of work, or place of the alleged infringement. Our lead supervisory authority is set out in Section 17.
We do not make decisions producing legal or similarly significant effects about you based solely on automated processing, including profiling, through the Website. Analytics and advertising tools may segment audiences in aggregate, but this is not used to make decisions about you individually.
The Website and our services are directed at adults and are not intended for children. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us so we can delete it.
The Website may contain links to third-party websites or resources. We are not responsible for the privacy practices or content of those third parties. We encourage you to review their privacy notices before providing them with personal data.
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, loss or destruction. These include encryption of communications in transit (TLS), access controls limiting access to authorised personnel on a need-to-know basis, and ongoing review of our safeguards. No method of transmission over the internet is entirely secure; we cannot guarantee absolute security, but we work to protect your data and to respond appropriately to any incident.
We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements. The “Last updated” date indicates the current version. Where changes are material, we will take reasonable steps to bring them to your attention.
For any privacy-related enquiry, or to exercise your rights:
Polivar Management LTD — Marimax Business Center, Dimokratias Ave 44, Office 104/1st Floor, Paphos 8028, Cyprus · [email protected]
Our lead supervisory authority is:
Office of the Commissioner for Personal Data Protection (Cyprus) Office address: Kypranoros 15, 1061 Nicosia, Cyprus Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus Tel: +357 22 818 456 · Fax: +357 22 304 565 Email: [email protected] Website: www.dataprotection.gov.cy