Please note that the Company has no control over and is not responsible for any third-party websites, plug-ins or applications which may be accessible through links from our application. Clicking on those links may allow third parties to collect or share data about you. Third party websites are responsible for providing their own privacy policies and notices which you will need to consider before you submit any personal data to such third-party websites.
Mirror 3D Lab is a Company offering services that include the development of mobile phone applications, research on innovation technologies, Virtual and Augmented Reality applications, digital assets for game development, 3D scanning and modeling. We are based in Paphos, Cyprus and our offices are situated at Alexandrou Papagou 79, 8027 Paphos, Cyprus.
We recognise and value the trust that individuals place in us when they provide us with their personal data, and we are committed to ensuring the confidentiality and protection of any personal data entrusted to us. All our partners, associates and employees are provided with the appropriate training for handling personal data securely and in accordance with the law. We also ensure that all business partners and external service providers we work with comply with their respective legal obligations and apply the same high standards when it comes to the protection of personal data and privacy.
We collect the following personal data that is necessary for the purpose of allowing you to create a user’s account and track your aerodynamic cycling posture in real-time through our Smart Cyclo App. These include:
We do NOT share any personal (including location data) or other user information with any third party.
We will process all your personal information lawfully, fairly, and in a transparent manner at all times.
We do not make any decisions concerning you based solely on automated decision-making processes or profiling.
We collect or receive your personal data in the following ways:
We collect and process your personal data only for the purposes that we are permitted to do so by applicable law and in particular (depending on our relationship with you):
Your location is captured during the ride and used to estimate the distance covered and then calculate the speed. Using this information, we can analyse the average speed for each different position held by the cyclist which is crucial for our application. To record the background location, you must give your consent in the relevant dialog that appears in the first use. If you choose to save the ride data, then the location information is also stored. If you choose to delete a saved ride, then all data including the recorded location information, is deleted.
Generally, to receive payment for our services, to ensure the security and health of our staff and premises, to monitor the App to ensure a smooth and seamless operation and that any software issues will be resolved, etc.
Where your prior consent is required under applicable law, you will be presented with a relevant consent form in relation to any such use and you may withdraw your consent at any time.
You do not have an obligation to provide us with your personal data. If, however, you do not do so we may not be able to provide you with our services.
We use third parties who provide Information Technology services to us which are relevant to the electronic storage of and access of your data to the extent this is necessary for the purpose of allowing us to provide our relevant services to you and generally to ensure that our legitimate interests are duly protected.
While we recognise that the storage and transmission of information, especially over the internet, cannot be guaranteed to be secure from intrusion by third parties, for the storage and security of your personal data the Company takes all the necessary physical, technical and organisational measures to protect personal data from unauthorised access, use, disclosure, alteration or destruction and to ensure that the processing is carried out in accordance with the law and the GDPR (access control, antivirus, firewalls, encryption, etc).
Information stored on our service providers’ servers is only accessed and used subject to strict security policies and standards agreed with them, to ensure the confidentiality of personal data.
Within the Company, your personal data is accessible only to those who need to access it for the purposes specified in paragraph 4 above, with a duty of confidentiality.
Outside the Company, recipients of your personal data may include subcontractors, agents and third-party service providers, such as Information Technology and related service providers who provide technical services such as software development, installation and maintenance, cloud storage services, file backup, recovery and continuity, etc.
For the purposes of compliance with our legal or regulatory requirements, external recipients of your personal data may also include regulatory authorities or law enforcement agencies in connection with enquiries, proceedings, or investigations anywhere in the world.
We choose our associates and external service providers very carefully, after carrying out all necessary checks and obtaining sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the processing will meet the requirements of this GDPR and applicable law.
To the extent any other third parties are considered “controllers” under the GDPR any processing of your personal data carried out by them is not under our control and we are not responsible for and do not endorse or monitor their content or privacy policies (if any).
Your location information is stored on the servers of third-party cloud storage service providers in encrypted form.
We keep your personal data only for as long as necessary to fulfill the purposes for which it was collected or any other relevant permitted purpose (subject to legitimate interest or regulatory requirements), or-in the case of consent-until you withdraw your consent.
After this period, your personal data will be irreparably destroyed.
If your personal data will be transferred to entities or other third parties whose headquarters or place of business is not located in the European Union (EU) or the European Economic Area (EEA), we ensure before forwarding the data, that outside of legally permitted exceptional cases pertaining to the recipient (reasons of public interest or recipient’s consent), an appropriate level of data protection exists (e.g. through an adequacy decision of the European Commission or through the use of Standard Contractual Clauses approved by the European Commission for these purposes, after due assessment of the law and the practice of the third country).
In accordance with the GDPR and applicable data protection laws, you may have the following rights in relation to the personal data that we hold about you:
You may exercise any of the above rights by contacting us by email at email@example.com.
If you wish to complain about the way we may have handled your personal information, you may contact us at the above email address and telephone number. We will examine your complaint and contact you to try and resolve the matter.
If you still feel that your personal information has not been handled appropriately according to the law, you can submit your complaint with the Office of the Commissioner for Personal Data Protection in Cyprus.