Privacy Policy


This Privacy Policy of the APL group is effective regarding all information that can be online found at,,,,, and other corporate sites of the Company.

1. Definitions

a. This Privacy Policy uses the following definitions:

1.1.1 Site Administration (hereinafter, Administration) are collectively called Company’s employees who act on behalf of the APL Group and who manage and/or organize personal data processing, determines the aims of data processing, content of personal data that must go through processing and actions that should be done to the personal data.

1.1.2 Personal data is any information relating directly or indirectly to a particular or defined individual who is the subject of the personal data.

1.1.3 Personal data processing means any measure (action) or a series of measures (actions) done to the personal data with the use of automatic algorithms or without such, including collection, recording, systematization, accumulation, storage, refinement (update, change), extract, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of the personal data.

1.1.4 Personal data confidentiality means a strict requirement for the Operator or another person who has obtained access to personal data to prevent its disclosure without the consent of the subject of personal data or without any other legal cause.

1.1.5 Site User (hereinafter User) means a person having access to the Site via the Internet and using the Site.

1.1.6 “Cookies” is a short piece of data sent by the web server and stored on the user's computer, which the web client or web browser sends to the web server each time when using a HTTP request while trying to open the page of the corresponding site.

1.1.7 IP-address means a unique network address of a node within a computer network built over HTTP.


a. Using this Site automatically means User’s consent with this Privacy Policy and the terms of personal data processing.

b. In case of disagreement with the Privacy Policy, the User must stop using the Site.

c. This Privacy Policy is effective regarding APL Group corporate Site. The Administration of the Site does not maintain or in charge of third parties’ web sites that a User can access using the links found on the Site.

d. The Administration does not verify the personal data provided by the User.


a. This Privacy Policy requires the Administration to protect the privacy and to avoid the disclosure of the personal data that the User provides when signing in the Site or making an order of APL Products at the Site.

b. The personal data that can be processed under this Privacy Policy is provided by the User by filling out a registration page (questionnaire) on the Site and includes the following information:

I. User’s Full Name;

II. User’s Contact Phone Number;

III. E-mail;

IV. Place of Residence;

V. ID/passport number;

c. The Site protects the data that is transferred automatically when viewing ads or visiting pages that have statistic system script ("pixel"):

 IP address;

 cookies info;

 info on your browser (or other app that provides ads viewing);

 time of access;

 online address where the ads is located;

 referrer (address of the previous page).

3.3.1. Disabling cookies may result in inability to access some pages of the Site that require authorization.

3.3.2. The Site Administration collects visitors’ IP-address statistics. This information is used to identify and solve technical problems, and to control the legality of financial payments.

d. Any other personal data not specified above (purchase history, used browsers, operating systems and etc.) is subject to safe storage and non-dissemination, except as set in articles 5.2. and 5.3. of this Privacy Policy.


a. Administration is allowed to use the User’s Personal Data for the following purposes:

I. Registered User’s Identification, to make an order and/or to make the Agreement for the Purchase of Products.

II. To provide the User with access to Site pages that provide personalized services;

III. Establishing feedback with the User, including sending notifications, inquiries regarding the use of the Site, service provision, processing requests and claims coming from the User.

IV. To determine the location of the User to ensure security, prevent fraud.

V. To confirm the accuracy and completeness of personal data provided by the User.

VI. To create a User’s account to make purchases, if the User has agreed to create an account.

VII. To inform the User about the order status.

VIII. To process and receive payments, to confirm taxes or tax relief, to dispute a payment, to determine the right to receive a credit line by the User.

IX. To provide the User with effective customer and technical support in case of problems related to the use of the Site.

X. To provide the User with product updates, special offers, pricing information, newsletters and other information on behalf of the Site if he or she provides their consent to receive such information.

XI. To make advertising efforts if the User provides their consent.

XII. To provide Site access to the User in order to obtain products, updates and services.



a. Personal data processing is made for an unlimited period of time by any legal means including within personal data information systems using automatic algorithms or without such.

b. The User agrees that the Site Administration has the right to transfer personal data to third parties, in particular, to delivery services, postal service organizations, telecommunication operators, solely for the purpose of delivering the User’s order placed on the Site, including delivery of the Products.

c. User's personal data may be transferred to the authorized state authorities in compliance with the legislation of the User’s country only and by the procedure established by the legislation of the User’s country.

d. In case of loss or disclosure of personal data, the Site Administration informs the User about the loss or disclosure of personal data.

e. The Site Administration takes the necessary organizational and technical measures in compliance with the personal data privacy legislation, to protect the User’s personal data from unauthorized or accidental access, destruction, update, blocking, copying, dissemination, as well as from other unlawful actions of third parties.

f. The Site Administration together with the User takes all necessary measures to prevent damages or other negative consequences caused by the User’s personal data loss or disclosure.


a. The User is obliged to do the following:

I. Provide personal data required to use the Site.

II. Update and/or supplement the personal data provided if it has been changed.

b. The Site Administration is obliged to do the following:

I. Use the provided information solely for the purposes specified in article 4 of this Privacy Policy.

II. Ensure the storage of confidential information in secret, avoid its disclosure without the prior written consent of the User, and avoid its selling, exchanging, publishing, or disclosure in any other possible way of the provided User’s personal data, except for article 5.2. and 5.3. of this Privacy Policy.

III. Take all necessary precautions regarding protection of the confidentiality of the User’s personal data in compliance with the procedure normally used to protect this type of information in existing business transactions.

IV. Block personal data concerning the particular User upon receipt of the request from such User, or his legal representative or authorized body for the rights protection of personal data subjects while verifying in case of unreliable personal data or unlawful actions.



a. The Site Administration, which has not fulfilled its obligations, is liable for damages incurred by the User because of the unlawful use of personal data in compliance with the laws of the Republic of Cyprus, except as provided in articles 5.2., 5.3. and 7.2. of this Privacy Policy.

b. The Site Administration shall not be responsible for loss or disclosure of the provided confidential information if it:

I. Had become disclosed before its loss or disclosure;

II. Had been transferred by third party before the Site Administration received it;

III. Had been disclosed with User’s consent.



a. It is mandatory to file a claim (a written proposal to settle the dispute voluntary) before filing a dispute lawsuit arising from the relationship between the Site User and the Site Administration.

b. The party that received the claim shall notify the other party in writing of the results of the consideration of the claim within 30 calendar days upon receipt of the claim.

c. If the agreement is not reached, the dispute will be submitted to the judicial authority in compliance with the current legislation of the Republic of Cyprus, and the authorized courts in the city of Nicosia have the exclusive jurisdiction to settle such dispute.

d. The current legislation of the Republic of Cyprus is effective to this Privacy Policy and the relationship between the User and the Site Administration.


9.1. The Administration has the right to make changes to this Privacy Policy without the User’s consent.

9.2. A new Privacy Policy becomes effective upon its online publication on the Sire, unless otherwise provided by the new version of the Privacy Policy.

9.3. All suggestions or questions about this Privacy Policy should be sent through feedback in the User's personal account.