Updated on December 28, 2020

1. Parties and Purpose

Totatus Limited
Xenofanous Street 5 - 4046 Limassol - Cyprus
BCE / VAT : CY 103 592 16P
Telephone: +357 96 03 47 04

Totatus Limited establishes the present Privacy Policy, the purpose of which is to inform in all transparency the Users of the website hosted at the following address:
, (hereafter the "Site"), of the manner in which personal data is collected and processed by Totatus Limited.

The term "User" refers to any user, either a natural or legal person, who visits or interacts in any way with the Site.

In this respect, Totatus Limited determines all the technical, legal and organisational means and purposes of processing the personal data of Users. To this end, Totatus Limited undertakes to take all necessary measures to ensure that the processing of personal data complies with the Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter "the Law") and the European Regulation of 26 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter "the Regulation").

Totatus Limited is free to choose any natural or legal person who processes the personal data of users at its request and on its behalf (hereinafter the "Subcontractor"). If necessary, Totatus Limited undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organisational security measures for the processing of personal data, with regard to the Law and the Regulations.

2. Processing of personal data

The use of the Site by Users may involve the communication of personal data. The processing of this data by Totatus Limited, in its capacity as Data Controller, or by service providers acting in the name and on behalf of Totatus Limited, will be in accordance with the Law and the Regulations.

Personal data will be processed by Totatus Limited, in accordance with the purposes mentioned below, via :

- the use of cookies
- subscription to the Newsletter
- participation in contests
- ordering items
 - any other action of registration of personal data explicitly accepted by the visitor

3. Purpose of the processing of personal data

In accordance with Article 13 of the Regulations, the purposes of the processing of personal data are communicated to the User and are as follows:

- to ensure the performance of the services offered and agreed upon on the site such as the sale of goods
- ensure the control of the execution of the proposed services
 - the realization of advertising and marketing campaigns

4. Personal data that may be processed

The User consents, when visiting and using the Site, that Totatus Limited collects and processes, according to the terms and principles described in this Privacy Policy, the following personal data:

The information of Users that they give for contractual purposes and to enable the proper performance of reciprocal obligations, namely, without limiting this non-exhaustive enumeration, the surname, first name, address, company information, e-mail address, telephone number, date of birth.

5. Consent

By accessing and using the Site, the User declares that he or she is aware of and agrees freely, specifically, knowingly and unequivocally to the processing of personal data concerning him or her. This agreement relates to the content of this Privacy Policy.

Consent is given by the positive act by which the User has ticked the box proposing the Privacy Policy in the hyperlink. This consent is an indispensable condition to carry out certain operations on the Site or to allow the User to enter into a contractual relationship with Totatus Limited. Any contract between Totatus Limited and a User concerning the services and goods offered on the Site is subject to the User's acceptance of the Privacy Policy.

The User consents that the Data Controller processes and collects, in accordance with the methods and principles included in this Privacy Policy, his personal data which he communicates on the Site or in the course of the services offered by Totatus Limited, for the purposes indicated above.

The User has the right to withdraw his consent at any time. Withdrawal of consent does not compromise the lawfulness of the processing based on the consent previously given.

6. Length of time Users' personal data is kept

In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller shall only keep personal data for the time reasonably necessary to allow the fulfilment of the purposes for which they are processed.

This duration is in any case less than : 1 year

7. Data Recipients and Disclosure to Third Parties

Personal data may be passed on to employees, collaborators, subcontractors or suppliers of Totatus Limited who offer adequate data security guarantees and who collaborate with Totatus Limited in the context of the marketing of products or the provision of services. They act under the direct authority of Totatus Limited, and are in particular responsible for collecting, processing or subcontracting this data.

In all cases, the recipients of the data and those to whom the data has been disclosed shall comply with the content of this Privacy Policy. Totatus Limited assures that they will process this data for the sole purpose intended, in a discreet and secure manner.

Should the data be disclosed to third parties for the purposes of direct marketing or canvassing, the User will be informed beforehand so that he can express his consent to the use of this personal data.

8. Data Protection Officer (DPO)

The following person is appointed Data Protection Officer (hereafter "DPO"): Sylvain Collard

The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.

The DPO can be contacted as follows:

9. Rights of Users

At any time, the User may exercise his rights by sending a message by e-mail to the following address:, or a letter by post, enclosing a copy of his identity card to the following address: Rue Pont-D'Avroy 48, 4000 Liège

a. Right of access

In accordance with article 15 of the Rules, Totatus Limited guarantees the User's right of access to his personal data. The User has the right to obtain access to the said personal data as well as the following information:

the purposes of the processing ;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data has been or will be communicated, in particular recipients who are established in third countries or international organizations;
where possible, the intended period of retention of the personal data or, where that is not possible, the criteria used to determine that period ;
the existence of automated decision making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, relevant information concerning the underlying logic, as well as the importance and the expected consequences of the processing for the data subject
The Data Controller may charge a reasonable fee based on administrative costs for any additional copies requested by the User.

Where the User submits such a request electronically (e.g. via e-mail address), the information is provided in a commonly used electronic form unless the User requests otherwise.

A copy of the User's data will be provided to the User no later than one month after receipt of the request.

b. Right of rectification

Totatus Limited guarantees the right of rectification and deletion of personal data to the user.

In accordance with Article 16 of the Regulations, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User first makes the necessary changes himself/herself from his/her user/other account, unless these changes cannot be made independently, in which case a request can be made to Totatus Limited.

In accordance with Article 19 of the Regulations, the Data Controller shall notify each recipient to whom the personal data has been communicated of any rectification of the personal data, unless such communication proves impossible or requires disproportionate efforts. The Controller shall provide the data subject with information about such recipients if the latter so requests.

c. Right to erasure

The User has the right to obtain the deletion of his/her personal data as soon as possible in the cases listed in article 17 of the Regulations.

Where the Controller has made the personal data public and is required to erase them pursuant to the previous paragraph, the Controller, taking into account the available technologies and the costs of implementation, shall take reasonable measures, including technical measures, to inform the other controllers who process such personal data that the data subject has requested the erasure by such controllers of any link to such personal data, or of any copy or reproduction thereof.

The two preceding paragraphs shall not apply to the extent that such processing is necessary:

for the exercise of the right to freedom of expression and information;
to comply with a legal obligation which requires the processing to be carried out in accordance with Union law or the law of the Member State to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for the establishment, exercise or defence of legal claims.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been communicated of any erasure of personal data or any limitation of the processing carried out, unless such communication proves impossible or involves a disproportionate effort. The data controller shall provide the data subject with information on such recipients if the latter so requests.

d. Right to limit processing

The User has the right to obtain the limitation of the processing of his/her personal data in the hypotheses listed in article 19 of the Regulations.

In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate effort. The Controller shall provide the data subject with information about such recipients if the latter so requests.

e. Right of data portability

In accordance with article 20 of the Rules, Users have the right to receive from Totatus Limited their personal data in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another data controller without Totatus Limited obstructing this in the cases provided for in the Rules.

When the User exercises his/her right to data portability pursuant to the previous paragraph, he/she has the right to obtain that personal data be transmitted directly from one data controller to another, where technically possible.

The exercise of the right of data portability shall be without prejudice to the right of erasure. This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The right of data portability does not affect the rights and freedoms of third parties.

f. Right of opposition and automated individual decision making

The User has the right at any time to object to the processing of his personal data due to his particular situation, including the automation of the data carried out by Totatus Limited. In accordance with article 21 of the Regulations, Totatus Limited will no longer process personal data, unless there are legitimate and compelling reasons for the processing which prevail over the interests and rights and freedoms of the User, or for the establishment, exercise or defence of rights in court.

When personal data is processed for canvassing purposes, the User has the right to object at any time to the processing of personal data concerning him/her for such canvassing purposes, including profiling insofar as it is related to such canvassing.

When the data subject objects to the processing for canvassing purposes, the personal data is no longer processed for such purposes.

g. Right of complaint

The User has the right to lodge a complaint concerning the processing of his personal data by Totatus Limited with the Data Protection Authority, competent for the Cypriot territory. Further information can be found on the website:

You can lodge a complaint at the following addresses:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Phone + 32 2 274 48 00
Fax + 32 2 274 48 35

The User may also file a complaint with the Court of First Instance of his domicile.

10. Cookies

The Site uses cookies to distinguish the Users of the Site. This helps to provide Users with a better browsing experience and an improvement of the Site and its content. The objectives and modalities of cookies are contained in this article.

a. General principles

A "Cookie" is a file that is temporarily or permanently deposited on the User's hard disk when consulting the Website, with a view to later connection. Thanks to cookies, the server recognizes the User's computer.

Cookies can also be installed by third parties with whom Totatus Limited collaborates.

Some of the cookies used by Totatus Limited are necessary for the proper functioning of the Website, others make it possible to improve the User's experience.

The User can personalize or deactivate cookies by setting the parameters of his browser.

By using the Website, the User expressly agrees with the management of cookies as described in this article.

b. Type of cookies and purposes

Different types of cookies are used by Totatus Limited on the Site:

The technical cookies: they are necessary for the operation of the Website, allow the communication of the data introduced and are intended to facilitate the navigation of the User;
Cookies for statistical and audience measurements: these cookies allow the recognition of the User and are used to count the number of Users of the Website over a certain period of time. Since they also indicate browsing behavior, they are an effective way to improve the User's browsing by displaying proposals and offers that may be of interest to the User. They also allow Totatus Limited to identify possible bugs on the Website and to correct them.
Functional cookies: these cookies facilitate the use of the Website by retaining certain choices introduced (for example, user name or language);
Cookies of tracking: Totatus Limited uses cookies of tracking via Google Analytics, to measure the interaction of the Users with the contents of the Website and to produce anonymous statistics. These statistics enable Totatus Limited to improve the Website. Google supports the explanation of these cookies at the following address:

c. Cookie Retention Time

Cookies are kept for the time necessary to accomplish the purpose for which they were created. The cookies that may be stored on the User's hard drive and their retention period are as follows:

- 1 year maximum

d. Cookie management

If the User does not want the Website to place cookies on his/her hard disk, it is easy for him/her to manage or delete them by modifying the parameters of his/her browser. Browser programming also allows the User to receive a notice or notification whenever a Website uses cookies and to decide whether to accept or reject them.

If the User disables certain cookies, the User accepts that the Website may not function optimally. Certain parts of the Website may not be usable, or may only be partially usable.

If the User wishes to manage and/or delete certain cookies in this way, he or she can do so by using the following link(s):

For Users with the following browser:

Internet Explorer:
Microsoft Edge:
If the User does not want Google Analytics cookies to be used, he or she is invited to set his or her browser to this effect on the following website:

11. Limitation of liability of the Data Controller

The Website may contain links to other websites owned by third parties not related to Totatus Limited. The content of these sites and their compliance with the Law and Regulations is not the responsibility of Totatus Limited.

The holder of parental authority must give his express consent for a minor under 16 years of age to disclose personal information or data on the website. Totatus Limited strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for collecting and processing information and personal data from minors under 16 years of age whose consent is not effectively covered by that of their legal parents or for incorrect data - particularly concerning age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he/she is under 16 years of age.

Totatus Limited is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or following computer attacks.

12. Security

The Data Controller implements organizational and technical measures to ensure an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation with regard to the nature, context and purposes of the processing of personal data.

The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.

13. Modification of the Privacy Policy

Totatus Limited reserves the right to modify this Privacy Policy in order to comply with legal obligations in this matter. The user is therefore invited to regularly consult the Privacy Policy in order to be aware of the modifications and adaptations. Any such modification will be posted on the Site or sent by e-mail for purposes of enforceability.

14. Applicable law and jurisdiction

This Privacy Policy is governed exclusively by Cypriot law. Any dispute will be brought before the courts of the judicial district of the registered office of Totatus Limited.

15. Contact

For any questions or complaints relating to this Privacy Policy, the User may contact the Data Controller via the following address:

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