TERMS AND CONDITIONS
The Terms and Conditions (hereinafter «T&C»), as they may be altered or amended from time to time by Ilona Markosyan (hereinafter: «Owner»), will apply, regulate and govern the Website’s use by a User. The T&C come into effect as of the 1st day of October 2024.
The use and/or access of any part of the Owner’s Website signifies the User’s consent and that the User agrees that they have read, understood and agreed to be legally bound by the T&C and the Privacy Policy. If the User does not agree to be bound by the T&C or the Privacy Policy, the User must not use or access any part of the Website or transfer, upload or download any data through the Website. The Owner may alter or amend the T&C without providing notice to the User and, therefore, it is the User’s sole responsibility and obligation to regularly monitor the T&C for any such alterations or amendments, prior to using the Owner’s Website.
THE OWNER AND SERVICES
1.1 Ilona Markosyan, is a Licensed Counseling Psychologist, L.N. 21081 (Cyprus) and L.N. 21174 (Greece), hereinafter referred to as the Owner.
1.2 The Owner provides Psychological Services, including but not limited to Psychological consultations, hereinafter referred to as the Services.
1.3 The Owner may upload and/or otherwise make available for display and/or download on the Website certain information and/or data with regards to or in connection with the Services it provides, including but not limited to website links and/or other links which lead to third party website’s and/or content. All and any data and/or information displayed and/or contained on the Website are provided for information purposes only and the Owner makes no representations as to its accuracy, efficiency or completeness. Such data and/or information is intended to be for informational purposes only and the User should not rely upon such data and/or information. The use in any way of the Website by the User, does not automatically create and/or establish a service provider -client relationship.
USE OF THE WEBSITE
2.1 Subject to the User’s consent and compliance with the T&C and Privacy Policy, the Owner provides the User with the non-exclusive right to use the Website, and any information and/or content is made available by the Owner to the User for informational purposes and for any other purposes expressly stated in the T&C.
2.2 The use of the Website by the User, does not provide the User with any intellectual property rights, such as trademarks, logos etc and does not provide any User with ownership of or any rights to any data that may be provided via use of the Website.
Unless expressly stated in the T&C and only to such extent, the User may not copy, use, reproduce, display, represent, sublicense, circulate or distribute in any way any data which is made available by the Owner, or by any other User, on the Website without the written consent of the owner.
2.3 The User is prohibited to use the Website and any data made available to the User in relation to use of the Website in any way which may interfere with any third party’s ability or right to use the Website and/or the Owner’s ability to provide its Services. Prohibited use of the Website includes but is not limited to, violation or infringement of any party’s right, impersonating any other entity or person, using a false identity, submission of misleading or false information to the Owner, breach of any domestic or international legislation or regulation.
USER CONSENT
3.1 The consent of the User is necessary in order for the User to access and/or download any information and/or data made available by the Owner on the Website, for the processing and collection of the User’s personal data by the Company, as well as for the Owner to contact the User with regards to the Services provided by the Owner.
3.2 The User provides such consent to the Owner, by actively agreeing to be bound by the Privacy Policy and T&C, (positive opt-in) the moment the User proceeds to download any information and/or data from the Website, as well as at the moment that the User proceeds to convey and/or upload any information and/or data, including personal data, through the Website to the Owner.
3.3 The User may at any time withdraw such consent, which was already provided to the Owner by the User, by contacting the Owner and requesting the same.
3.4 In respect of our User’s free consent, the Website does not use pre-ticked boxes
3.5 The contact information of our Data Processor is listed down below in the contact information bar
3.6 Any Data Processing taking place on this Website is operated in a legitimate interest of the User and of the Owner, according to the governing laws of the EU and the Republic of Cyprus.
3.7 If you have any remarks or complaints regarding the way we process your personal data, we invite you to contact our DPO by sending an email to info@ilonamarkosyan.com, marking ”my personal data” in the subject field and your request will be processed from our Data Processor within 72 hours upon receipt.
NOTIFICATION OF BREACH
4.1 In the event that there shall be a breach to the personal data and/or information kept by the owner, the Owner shall provide notice to any affected User within 5 (five) business days from the date that the Owner has become aware of such breach.
4.2 In the event that there shall be a breach to the personal data and/or information kept by the Owner, the Owner shall provide notice to the Commissioner of Data Protection within seventy two (72) hours from the awareness of the breach.
DATA AND PERSONAL DATA
5.1 The User acknowledges that, by and/or throughout the access and/or use of the Website by the User, and/or for the purpose of the Owner effectively providing its Services to the User, the Owner may collect information, content and/or data of any type and form, including the User’s personal data, as described below, links to websites, articles, publications or other types of information.
5.2 The Owner declares and the User acknowledges that personal data is collected by the Owner and that any links, articles, publications or other types of information made available on the Website is solely for informational purposes.
5.3 The Website allows the User to download or submit data. The submission, download or upload of the data by the User grants the Owner the consent to use, reproduce, and/or process such data for the purpose of effectively providing its Services.
5.4 The Owner’s website operates in compliance with the six (6) Data Protection Principles set by the GDPR, within the “Data Protection by Design and by Default” regulation as follows:
5.4.1. The Website operates in lawfulness, fairness and transparency
5.4.2. The Website operates in respect of the purpose limitation of the collection of data provided by the Users
5.4.3. The Website operates with accuracy
5.4.4. The Website operates in respect of the storage limitation principle
5.4.5. The Website operates with integrity and confidentiality
5.4.6. The Website operates in respect of the data minimization principle
5.5 The data collection operated by the Website is strictly limited to the necessary and is executed for specific purposes, according to the laws of the European Union and the Republic of Cyprus.
5.6 The Owner carries out a Data Protection Impact Assessments, hereinafter referred to as DPIA. The DPIA is a mechanism that aims to identify, evaluate and address the data protection risks to the rights and freedoms of natural persons associated with new activities involving personal data processing. Where there is a high risk to these rights and freedoms, the GDPR requires data controllers to carry out a DPIA.
THIRD PARTY DATA
6.1 The Owner may provide access through the Website to third party data, such as website links leading to websites of third persons and/or Governmental Departments. The Owner does not undertake any obligation to monitor, investigate or review any data submitted or provided otherwise by third persons or Users, any third persons providing any website links or their data and does not endorse any opinions, ideas or concepts of third party data.
6.2 The Owner is not responsible for any third party data, irrespective of its accuracy, availability or suitability, by any third party or for any action or omission of any third party. The Owner has the right, at its sole discretion, to alter, amend or delete any third party data. The User undertakes at all times any and all risks associated with accessing and/or obtaining any information and/or data over the internet and agrees that the Owner shall not be held liable or responsible for any damage or loss which is a direct or indirect result of the User’s use of third party data, services or websites.
6.4 In the event that any User objects to any third party data, such User may report such data to the Owner by contacting the Owner. Following the report, the Owner will address such data in its sole discretion and as deemed necessary by the Owner.
6.5 All data exchange on this Website is processed by our Data Controller.
6.6 Cross-boarder processing takes place within the boarders of the European Union.
6.7 In the event of any data exchange with third parties outside the boarders of the European Union, within a group of undertakings or enterprises engaged in a joint economical activity, the data control is subject to BCRs or to MCCs
USER’S WARRANTIES
The User hereby warrants that:
7.1. The User is of 18 years or over of legal age and of legal competence to understand and to be bound by the T&C and Privacy Policy.
7.2. In the event that the User is providing any information and/or data to the Owner through the Website on behalf of any third person, that the User is an authorized representative of such third person and that in such a case, the third person also agrees and accepts to be bound by the T&C and Privacy Policy.
7.3. The User is authorized to provide any information and/or data through the Website, in accordance with the Laws of the Republic of Cyprus and of any International Law.
7.4. That any information made known and/or provided through the Website by the User to the Owner and at the time that this is made known and/or provided, it is accurate, correct, valid and true.
DISCLAIMER OF WARRANTIES
8.1 The Owner explicitly does not warrant that the Website, use of the Website and any data relevant to the Website shall be secure, free of any delays, errors or inaccuracies or meet the User’s or any other requirements.
8.2 Other than any express warranties contained within the T&C, the owner does not make any warranties and hereby disclaims any implied warranties, including but not limited to warranty of suitability for a specific purpose, warranty relevant to any services which may be provided from and as a result of the use of the Company’s Website to the User, warranty of any third party data and/or services, irrespective of whether these were accessed by the Website or otherwise.
LIMITATION AND EXCLUSIONS
The User agrees and acknowledges that:
9.1. Relevant errors may occur with regards to or in connection with the Website.
9.2. The Owner shall not be held liable to the User or any third party for damages of any type or nature, including but not limited to damages with regards to lost data and/or profits, which may arise as a result of or in relation to the use of the Website.
9.3. The Owner has no liability or responsibility for failure to store or remove any data which is maintained or displayed in relation to the Website.
9.4. The Owner reserves the right at any time to add, alter, amend or erase any and all data and/or information made available in any way on the Website, in whole or in part, with or without provision of notice, and that the Owner shall not be held responsible or liable by the User or any third party in such cases.
INDEMNITY
10.1 The User agrees to indemnify and hereby indemnifies the Owner, any of its officers, employees and/or persons affiliated with the Owner, harmless from any loss, expenses, or damages which may arise in relation with any claim or action brought by any third party against them with regards to or in connection with the Website and/or any data and/or information conveyed through or made available on the Website.
10.2 The User agrees that in the event of any dispute with any other User or third party with regards to the Website or which is a consequence of the Website, the User releases the Owner, any of its officers, employees and/or persons affiliated with the Owner, from damages and claims of any nature or type.
PRIVACY
11.1 The User acknowledges and agrees that subject to obtaining the relevant consent, any of their personal information may be collected, processed and/or used to enable the Owner to provide the User with the Services. The User authorizes the Owner at all times to proceed with any of the above actions with regards to the User’s name, email address, street address, telephone number and other general information provided through the Website or otherwise made available by the User to the Owner through the Website.
11.2 The User has the right to cancel the authorization and consent provided to the Firm, at any time, upon written request to the Owner of the same.
11.3 Subject to the consent and active opt-in by the User, in accordance with Term 3 above, the User agrees that by the provision of any email address to the Owner, the Owner may send emails to the User and to such email addresses regarding marketing, advertising or any other content or with regards to the Services.
11.4 The User reserves the right to opt out of receiving emails from the Owner, as provided by Term 11.3 above, by providing written notice to the Owner of the same.
11.5 The User agrees that the Owner may provide the User with any legal notices via email.
DISPUTE RESOLUTION
12.1 The User hereby agrees that with regards to any and all disputes arising or relevant to the T&C, to the Privacy Policy or to the Services provided by the Owner, the User shall first contact the Owner by providing a description of the dispute and the contact details of the User, and providing the Owner with thirty (30) days in order for the Owner to undertake relevant investigations and attempt to resolve such dispute.
12.2 In the event that a dispute is not resolved within the aforementioned thirty (30) days, the User hereby agrees that the dispute will then be resolved in negotiation proceedings between the Owner and the respective User.
12.3 This Term shall in no way limit the Owner’s right to investigate reported violations or complaints with regards to the Website, the T&C, the Privacy Policy or the Owner’s Services or to take any actions deemed appropriate by the Owner, including but not limited to Court proceedings and contacting competent authorities and/or law enforcement officials.
FORCE MAJEURE
13.1 The Owner shall not be held liable for any non performance under the T&C, the Privacy Policy or with regards to provision of the Services which is due to any event beyond its reasonable control.
APPLICABLE LAW AND JURISDICTION
14.1 The applicable law to the T&C, the Privacy Policy, the performance and enforcement of any obligations, are the laws of the Republic of Cyprus.
14.2 The Courts of the Republic of Cyprus are the competent Courts with regards to resolution of any disputes which arise or are relevant to the T&C, the Privacy Policy, the Website, or the Services.
COPYRIGHT
15.1 The database and information of this website is protected by copyright law, trademark law, database rights and other intellectual property rights of the European Union and the Republic of Cyprus.
15.2 The database and information content of this website is subject to updating and revision, while the copyright owner remains the Owner at all times.
15.3. Ilona Markosyan, the Owner’s licensors and authorized contributors own the copyright, database right and all intellectual property rights on this website unless otherwise stated.
15.4. The User of this website may view, print, copy, download and save extracts of the data and/or information of this website through the website for personal use only, subject to the following non exhaustive list of conditions:
15.4.1. The use of the database content and/or information found on this website for commercial purposes or reproduction before any wide audience is strictly prohibited.
15.4.2. The modification of the database content and/or information found on this website is strictly prohibited.
15.4.3. The use of the database content and/or information found on this website for advertising purposes is strictly prohibited.
15.5 Copies of the database content and/or information may be provided by the User to third parties under the following non exhaustive conditions:
15.5.1. The copies of the database content and/or information can only be circulated for information or research purposes only.
15.5.2. The copies of the database content and/or information are not subject to any fee or monetary exchange
15.5.3. The copies of the database content and/or information are not subject to modification
15.5.4. The copies of the database content and/or information must always mention the Owner as the source
15.6 Any other use of the database content and/or information of this website is strictly prohibited, unless a written consent is granted by the Owner for a specific use.
15.7 All contributors of this website agree that the database content and/or information shall be available in a free form to everyone for their own use, in respect of the laws of the European Union and the Republic of Cyprus.
The present T&C notice has been updated on the 1st of October of 2024 by Ilona Markosyan. All rights reserved.
PRIVACY NOTICE
Welcome to the web page of Ilona Markosyan! Your privacy is important to us.
The present Privacy Notice sets out our step-by-step way of processing personal data, along with the client’s rights regarding that personal data.
In this document, Ilona Markosyan (hereinafter: “The Owner”), is the data controller of the client’s personal data. Any queries that may arise, regarding this Privacy Notice should be addressed to us in written form.
This Privacy Notice is in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”) and the governing Laws of the Republic of Cyprus.
SOURCES OF DATA
We collect your data in the following way:
From information/documents provided to us by you directly
From information/documents provided to us by your company or an intermediary
From our registered written or digital communications with you
From your agents, advisers, intermediaries and custodians of your assets
From public organizations or other third parties
From publicly accessible sources or background checks performed on you
From business cards
From Cookies on our website
TYPES OF DATA
Name and contact details
Financial information such as income, expenditure, assets and liabilities, sources of wealth, bank account details etc
Authentication data such as nationality, tax ID number, ID/Passport details, domicile etc Reference letters
CV
Personal information such as family status or personal circumstances, where appropriate
Information in respect of anti-money laundering legislation
Information regarding your public exposure
Any other information you may provide to us
Information that will help us to offer you the best possible services
LAWFUL BASIS FOR PROCESSING PERSONAL DATA
Client’s Consent
Performance of a contract
The vital interests of the data subject
The legitimate interests of the Data controller such as network and information security, prevention of fraud etc
Public interest or exercise of official authority
DATA RECIPIENTS
Owner’s Employees acquainted with the GDPR
Service Providers (banks, public authorities, legal, financial institutions) if necessary and appropriate to fulfil the purposes set out above Owner’s affiliates, partners, agents, sub-contractors
Courts or tribunals
Third parties for event or marketing purposes
Law enforcement agencies, where necessary and appropriate
Regulators or other governmental or supervisory agents with legal right or legitimate interest in the data information
Public registries
International recipients solely for the purposes of executing the services specified in the agreement between the Client and the Owner. International processing are strictly subject to the Client’s explicit consent and they only concern countries approved by the European Commission
DATA SUBJECTS RIGHTS
The right to be informed
The right of access to their personal data
The right of rectification of their personal data
The right of erasure of their personal data, except for the case of a lawful reason for continued processing
The right to restrict processing
The right to data portability
The right to object
The right no to be subject to automate decision-making such as profiling
DATA STORAGE
The Owner stores all personal data that has been collected, in accordance with the Data Retention Policy. The Owner creates a personal data protection file for each client and retains the file until the purposes for which the data was collected are fulfilled. Upon fulfilment of the purposes, the personal data is guarded in discretion for a maximum period of six (6) years, in accordance with the governing Laws of the European Union and the Republic of Cyprus, and at the expiration of that time period, the file is destroyed.
CONSENT
According to the new legislation, Data Subjects must be able to withdraw their consent any time with as much ease as giving it. The Data Subjects consent must be:
Freely given
Specific
Informed
Unambiguous
Balanced
Please note that you have the right to withdraw your consent, at any time, by sending us an email to the following email address:
Info@ilonamarkosyan.com
MARKETING
The Owner might send you marketing newsletter or invitations, regarding our services and information that may interest you. Your personal data shall not be shared to any third parties for commercial and marketing reasons. If you wish to receive marketing notifications from us, please contact us at the following email address:
Info@ilonamarkosyan.com
DATA BREACH
In the highly unlikely event of a breach of security, leading to accidental or unlawful destruction or/and unauthorized disclosure of data information, the Data Controller of Owner will send a written notification to the Client concerned and to the Data Commissioner of the Republic of Cyprus within seventy-two (72) hours from awareness of the breach.
Your security is vital to us and therefore the Owner has created a specific mechanism of breach detection. The measures adopted by our Data Protection Officer are listed down below:
Detection of the Breach
Report
Investigation
Pseudonymisation
Regular testing and evaluation
Procedures of timely restoration of availability and access in case of a technical accident
DATA PROTECTION OFFICER
Our Data Protection Officer (“DPO”) is the Owner’s partner responsible to collect and process the personal data provided by our Clients.
You can contact our DPO at the following email address:
Info@ilonamarkosyan.com
For any complaints you may also contact the Data Commissioner of the Republic of Cyprus at the website listed down below:
http://www.dataprotection.gov.cy
CHANGES TO THIS PRIVACY NOTICE
The present Privacy Notice is subject to change, according to the Laws relating to privacy and personal data. Any updates will appear on Owner’s website.
This Privacy Notice was last updated on the 1st October 2024.
DISCLAIMER OF WARRANTIES
The information provided and/or displayed and/or accessed on or through the website of Ilona Markosyan (hereinafter: «Owner») is intended to provide general information to the public and under no circumstance constitutes any form of psychological advice/psychotherapy or online therapy. Our associates and legal advisors update all material and regulations posted and/or displayed on or through the Owner’s website, but their accuracy cannot be guaranteed.
The Owner, including its officers and/or employees and/or associates and/or affiliates, expressly disclaims all responsibilities and warranties, conditions and terms, whether expressed or implied, with respect to any information exposed and/or displayed and/or accessed on or through the Owner’s website and/or in links contained herein, including but not limited to warranties of merchantability, fitness for a particular purpose and nonInfringement.
Please note that any link contained in this website, leading to a private, governmental, educational and/or other entity’s website does not, in any way, state or imply the existence of a relationship between the Owner and that entity and the Owner disclaims all responsibilities and warranties with regards to the same.
