Effective Date: 28/07/2025
Last Updated: 28/07/2025
Welcome to CADELI LTD (“CADELI”, “we”, “us”, or “our”). We are committed to safeguarding your personal data and respecting your privacy. This Privacy Policy outlines how we collect, use, share, and protect your personal information when you use our mobile application (“App”) available on Android and iOS devices.
Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.
1. About Us
CADELI LTD is a company registered in Cyprus. We operate a mobile platform that facilitates water delivery services through collaboration with local and international water suppliers. Our App enables users to subscribe to delivery services currently offered in Larnaca, Cyprus, with planned future expansion across the country.
Our website (www.cadeli.cy) is strictly informational and does not collect personal data or process orders.
2. Scope of This Privacy Policy
This Privacy Policy applies exclusively to:
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Users of the CADELI App on Android and iOS devices
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Personal data collected via the App for service delivery, subscriptions, and account management
This Policy does not apply to:
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Interactions with third-party water suppliers outside our App
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Visitors to the CADELI website who do not download or use our App
3. Legal Framework
CADELI LTD processes personal data in accordance with:
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The General Data Protection Regulation (GDPR) (EU) 2016/679
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Cyprus Law 125(I)/2018 on the Protection of Natural Persons with regard to the Processing of Personal Data
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Any other applicable local regulations
4. What Personal Data We Collect
We may collect and process the following categories of personal data:
a. Identity Data
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Full Name
b. Contact Data
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Phone Number
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Email Address
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Delivery Address / Location
c. Account & Authentication Data
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Google Account ID (when using Google sign-in)
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Apple iCloud ID (when using Apple sign-in)
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Mobile number (when using phone number sign-in)
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Email address (when manually signed up)
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Authentication tokens (encrypted)
d. Device & Usage Data
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IP Address
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Device type, model, and operating system (iOS or Android)
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App usage logs (e.g., login times, feature usage)
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Crash logs and diagnostics
e. Subscription Data
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Plan type (monthly/annual)
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Payment history and status (via payment gateway provider)
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Order history
5. How We Collect Your Data
We collect your data:
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Directly from you, when you:
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Create an account
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Enter your delivery location
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Subscribe to a water plan
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Contact support
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Automatically, when you:
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Use the App (via analytics and device permissions)
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Allow location access for delivery coordination
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6. Purposes for Data Processing
Your personal data is processed for the following purposes:
| Purpose | Legal Basis (GDPR) |
|---|---|
| Account creation and authentication | Article 6(1)(b) – Performance of a contract |
| Delivery of water to your specified location | Article 6(1)(b) |
| Managing subscriptions and payments | Article 6(1)(b) |
| Customer support and service notifications | Article 6(1)(b), (f) |
| App performance optimization | Article 6(1)(f) – Legitimate interests |
| Legal compliance (e.g., tax, consumer rights) | Article 6(1)(c) – Legal obligation |
| Marketing (only if user gives explicit consent) | Article 6(1)(a) – Consent |
7. Sharing of Personal Data
CADELI LTD does not sell your personal data.
We may share your data with:
a. Service Partners (Data Processors)
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Local and international water distribution partners for order fulfillment
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Cloud infrastructure providers (e.g., Firebase, AWS)
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Payment gateway services (e.g., Credit card, Master Card, Apple Pay, Google Pay, etc.) – we do not store card details
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SMS and email notification services
b. Legal Authorities
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If required by law, regulatory authority, court order, or to enforce our Terms of Use
All third-party processors are contractually bound by Data Processing Agreements (DPAs) to maintain GDPR-compliant security and confidentiality.
8. How Long Do We Keep Your Data?
In accordance with Article 5(1)(e) of the General Data Protection Regulation (GDPR) and the guidelines of the Office of the Commissioner for Personal Data Protection of Cyprus, we retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:
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Service delivery (e.g., active subscriptions and order fulfillment)
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Legal and regulatory obligations (e.g., tax or accounting laws)
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Contract enforcement or legal claims
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Business continuity, fraud prevention, and system integrity
Retention Periods
| Data Category | Retention Period |
|---|---|
| Account information | Until account deletion or 6 years after inactivity |
| Order and transaction data | 6 years (tax and commercial law compliance) |
| Support correspondence | 2 years from resolution |
| Location and delivery logs | 12 months (unless linked to dispute) |
| Marketing consent records | Until withdrawn + 5 years for audit compliance |
If you delete your account or request data erasure, we will anonymize or securely delete your data, except where we are required to retain it under law (e.g., for tax, fraud prevention, or dispute resolution purposes).
We regularly review stored data to ensure it is not kept longer than necessary.
9. Your Rights Under GDPR
As a user in the EU and Cyprus, you have the following rights:
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Right to Access – Request a copy of the personal data we hold about you
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Right to Rectification – Correct inaccuracies in your data
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Right to Erasure (“Right to be Forgotten”) – Request deletion of your data
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Right to Restrict Processing – Limit how we use your data
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Right to Data Portability – Request your data in a portable format
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Right to Object – Object to certain processing, such as profiling or marketing
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Right to Withdraw Consent – Withdraw marketing consent at any time
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Right to Lodge a Complaint – With the Office of the Commissioner for Personal Data Protection (Cyprus)
To exercise these rights, please contact us at privacy@cadeli.cy
10. Data Security
CADELI implements industry-standard technical and organizational measures, including:
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End-to-end encryption for sensitive data
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Secure authentication for account access
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Firewalls and intrusion detection systems
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Regular security audits and vulnerability testing
While we take all reasonable steps to secure your data, no system is 100% secure. Users are responsible for keeping login credentials confidential.
11. Cross-Border Data Transfers
Some of our processors (e.g., Apple, Google) may store or process your data outside the EU. In such cases, we ensure that appropriate safeguards are in place, such as:
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Standard Contractual Clauses (SCCs)
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Data Protection Agreements
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Storage in jurisdictions with adequate data protection laws
12. Children’s Privacy
CADELI App is not intended for use by children under the age of 16. We do not knowingly collect personal data from anyone under this age. If we become aware of such collection, we will take immediate steps to delete the data.
13. Marketing and Notifications
We may send transactional notifications (e.g., delivery confirmations, subscription status) as part of our services.
We will only send marketing communications if:
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You have explicitly consented
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You may opt out at any time via in-app settings or by emailing us at unsubscribe@cadeli.cy
14. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will:
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Post the updated version on the App and website
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Update the “Last Updated” date at the top
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Notify you via the App if significant changes are made
15. Contact Us
For questions, concerns, or to exercise your data rights:
CADELI LTD
📍 Larnaca, Cyprus
📧 Email: privacy@cadeli.cy
🌐 Website: www.cadeli.cy