Policy version: [4 November 2024][ — for previous versions of this policy see here]
THREADBUTTON.COM (our website) is provided by A. CHR. KYTHREOTIS & SON LIMITED trading as Thread & Button (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).
Given the nature of our website, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18years old has been shared with our website please let us know so that we can delete that data.
This version of our privacy policy is primarily written for adults, including parents and guardians of child users.
This privacy policy is divided into the following sections:
This privacy policy relates to your use of our website only.
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
You must provide this personal data unless we tell you that you have a choice.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on [insert as appropriate, eg your use of our website or any services on it].
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
We collect personal data from you:
Under data protection law, we can only use your personal data if we have a proper reason, eg:
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
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What we use your personal data for |
Our reasons |
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Creating and managing your account with us |
To perform our contract with you or to take steps at your request before entering into a contract |
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Providing products AND/OR services to you |
To perform our contract with you or to take steps at your request before entering into a contract |
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Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us |
To comply with our legal and regulatory obligations
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Enforcing legal rights or defend or undertake legal proceedings |
Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect our business, interests and rights |
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Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website |
Depending on the circumstances: —your consent as gathered by Cookieplot —where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time. (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
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Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended |
Depending on the circumstances: —your consent as gathered see ‘Cookies [and other tracking technologies]’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by [insert details as appropriate] (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
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Communications with you not related to marketing, including about changes to our terms or policies or changes to the products AND/OR services or other important notices |
Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
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Protecting the security of systems and data used to provide the services |
To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
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Statistical analysis to help us understand our customer base |
For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
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Updating and enhancing customer records |
Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products |
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Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant and [insert] |
To comply with our legal and regulatory obligations |
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Marketing our services to existing and former customers |
For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information |
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To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
More details about how we use your personal data and why are set out [in the table below OR here [insert link to another webpage].]
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Purpose |
Processing operation |
Lawful basis relied on under the and EU GDPR |
Relevant categories of personal data |
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Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices |
Addressing and sending communications to you as required by data protection laws, ie: the EU GDPR |
Processing is necessary for compliance with a legal obligation to which we are subject ( |
—your name, address and contact information, including email address and telephone number [and company details] —your account details (username) |
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Addressing and sending communications to you as required |
Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) |
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Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) |
Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you |
—your name, address and contact information, including email address and telephone number [and company details] —your account details (username) |
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We will use your personal data to send you updates (by email, text message, telephone or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
We may ask you to confirm or update your marketing preferences if you ask us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell OR share it with other organisations.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
We routinely share personal data with:
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
More details about who we share your personal data with and why are set out [in the table below OR here [insert link to another webpage]].
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Recipient |
Processing operation (use) by recipient |
Relevant categories of personal data transferred to recipient |
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[Insert full legal name, eg Example Co 1 Ltd—a company incorporated in [Insert, eg England] with registered number [company number], whose registered office is at [Insert]] |
[Insert, eg: Web and data hosting services, ie stores a copy of your personal data on computer equipment so it can be accessed by us and permitted third parties (see below) online.] |
[Insert, eg for a hosting company: Any of the personal data we collect about you (see [add ‘here’ and insert link back to appropriate part of main policy]), except [insert as appropriate, eg location data]] |
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[Insert full legal name, eg Example Co 2 Ltd—a company incorporated in [Insert, eg England] with registered number [company number], whose registered office is at [Insert]] |
[Insert] |
[Insert] |
[We will not share your personal data with any other third party.]
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, [insert any particular examples].
Different retention periods apply for different types of personal data.
If you stop using your account we will delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
The EEA, Cyprus and other countries outside the EEA have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside Cyprus and EEA. In those cases we will comply with applicable Cyprus and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
[More details about the countries outside the EEA to which your personal data is transferred are set out [in the table below OR here [insert link to another webpage].]]
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Recipient country |
Recipient |
Processing operation (use) by recipient |
Lawful safeguard |
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United Kingdom |
[Insert full legal name (eg Example Co Ltd) and details of company registration number and registered address] |
[Insert] |
Adequacy decision: Commission Implementing Regulation (EU) 2021/1772 of 28 June 2021 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate protection of personal data by the United Kingdom |
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New Zealand |
[Insert full legal name (eg Example Co Ltd) and details of company registration number and registered address] |
[Insert] |
Adequacy decision: Commission Implementing Decision 2013/65/EU of 19 December 2012 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data by New Zealand |
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Example country without adequacy finding |
[Insert full legal name (eg Example Co Ltd) and details of company registration number and registered address] |
[Insert] |
Legally-approved standard data protection clauses for transfers from a controller to a processor recognised or issued further to Article 46(2) of the EU GDPR To obtain a copy of the [insert, eg standard data protection clauses], please contact [us OR our Data Protection Officer] (see ‘How to contact us’) |
If you would like further information about data transferred outside the EEA, please contact us (see ‘How to contact us’ below).
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies [and [insert details of any similar technologies, eg web beacons, action tags, single-pixel gifs]] on our website. These [insert details, eg help us recognise you and your device and store some information about your preferences or past actions].
For further information on cookies [and [insert details of any similar technologies, eg web beacons, action tags, single-pixel gifs]], our use of [insert, eg refer to ‘cookies’ and/or to relevant similar technologies], when we will request your consent before placing them and how to disable them, please see our [insert link to Cookie Policy].
You generally have the following rights, which you can usually exercise free of charge:
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Access to a copy of your personal data |
The right to be provided with a copy of your personal data |
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Correction (also known as rectification) |
The right to require us to correct any mistakes in your personal data |
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Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data—in certain situations |
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Restriction of use |
The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
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Data portability |
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
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To object to use |
The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
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Not to be subject to decisions without human involvement |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website |
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The right to withdraw consents |
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by [insert details as relevant depending on consents] Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the Officer of the Commissioner for personal data protection on your rights under the GDPR. https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/page1a_en/page1a_en?opendocument
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
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Our contact details |
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[Insert contact address] [Insert contact email address] [Insert contact telephone number] |
