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NOTICE 01 / VERSION 1.0

YOUR DATA.
YOUR CONTROL.

This notice explains how R.G Superpollo Digital Solutions LTD plans to use personal data when you unlock a free creative resource or optionally join its WhatsApp community.

CONTROLLER
R.G Superpollo Digital Solutions LTD
LOCATION
Larnaka, Cyprus
CONTACT
info@superpollods.com
LAST UPDATED
22 October 2026

01 / DATA WE COLLECT

ONLY WHAT THE
FLOW NEEDS.

This resource portal processes the following information:

  • Email address — required to unlock a resource and recognise an existing access session.
  • WhatsApp number — collected only if you actively choose the separate WhatsApp community option.
  • Consent record — your choice, the wording and policy version shown, and the date and time of that choice.
  • Resource activity — the resource selected and the date and time it was unlocked.
  • Rate-limit data — a short-lived pseudonymous key derived from the IP address, used to enforce a maximum of two resource unlocks in a rolling seven-day period. The raw IP address is not stored in the lead spreadsheet.
  • Basic technical logs — information normally generated by the website host for security and reliable delivery, such as request time, browser information and error logs.

We do not ask for special-category data through this portal. Please do not send sensitive personal information through the form.

02 / WHY WE USE IT

PURPOSE BEFORE
PROCESSING.

REQUESTED ACCESS

To validate the form, unlock the resource you selected and remember access for up to 30 days.

Legal basis: steps taken at your request to provide the resource (GDPR Article 6(1)(b)).
SECURITY + FAIR USE

To prevent automated abuse and apply the limit of two resource unlocks per IP in a rolling seven-day period.

Legal basis: our legitimate interest in protecting the portal and keeping access fair (GDPR Article 6(1)(f)).
WHATSAPP COMMUNITY

To send an invitation and occasional community updates only when you select the optional WhatsApp choice.

Legal basis: your consent (GDPR Article 6(1)(a)). You may withdraw it at any time.
COMPLIANCE

To record consent choices, answer rights requests and meet legal obligations.

Legal basis: legal obligations and legitimate interests, as applicable.

Your email is not automatically enrolled in a marketing newsletter by requesting a resource. Any future email marketing would require its own clear choice where legally required.

03 / SERVICE PROVIDERS

WHO HELPS US
DELIVER IT.

We do not sell personal data. Access may be limited to R.G Superpollo Digital Solutions LTD and service providers needed to operate this flow:

  • Website hosting and security providers, for hosting, logs, protection and reliable operation.
  • Google Workspace, Google Sheets and Google Drive, for the lead backup and delivery of resource folders. Opening a resource also places you under Google’s own privacy terms.
  • WhatsApp / Meta, only if you opt in to receive the community invitation or communicate with us there. Your use of WhatsApp is also governed by WhatsApp’s own privacy notice.

Some providers may process data outside the European Economic Area. Where required, we will rely on an applicable adequacy mechanism or contractual safeguards and make further information available on request.

GOOGLE PRIVACY WHATSAPP PRIVACY

04 / RETENTION

KEPT FOR A
DEFINED REASON.

  • The signed access session remains active for 30 days, so a returning visitor does not have to complete the form for each resource.
  • The pseudonymous rate-limit key expires after the rolling seven-day limit and a short technical cleanup period.
  • Lead and download records are reviewed and deleted or anonymised when no longer needed. The maximum is 24 months after the last interaction, unless a shorter period applies or retention is required to establish, exercise or defend legal claims.
  • Evidence of consent or withdrawal may be retained for the period reasonably necessary to demonstrate compliance.

This notice will be updated if the systems require a different, justified retention period.

05 / YOUR CHOICES

ACCESS IS NOT
MARKETING CONSENT.

Your email is required for the resource-unlock service. Providing a WhatsApp number and joining the community are optional. Leaving the WhatsApp box unticked will not prevent you from accessing an eligible resource.

You can withdraw WhatsApp consent at any time by leaving the community, asking us in WhatsApp, or emailing info@superpollods.com. Withdrawal does not affect processing that was lawful before it.

The portal uses a strictly necessary signed access token to remember an unlocked session for up to 30 days. It is not used for advertising. The cookie notice will be updated if analytics or other non-essential technologies are later added.

06 / YOUR RIGHTS

YOU STAY IN
CONTROL.

Subject to the GDPR and any applicable limitations, you may ask for access to your personal data, correction, deletion, restriction, portability, or object to processing based on legitimate interests. You may also withdraw consent at any time.

We do not plan to use the portal data for automated decision-making or profiling that produces legal or similarly significant effects.

If you believe your data has been handled unlawfully, you may complain to the Cyprus Office of the Commissioner for Personal Data Protection. We would appreciate the opportunity to address your concern first.

CYPRUS DATA PROTECTION AUTHORITY

07 / CONTACT

ASK US
DIRECTLY.

For a privacy question, a rights request or withdrawal of WhatsApp consent, contact:

R.G Superpollo Digital Solutions LTD
Larnaka, Cyprus
info@superpollods.com

We may ask for limited additional information when reasonably necessary to confirm your identity before fulfilling a rights request.