Privacy Policy

Last updated: 05.06.2026

This Privacy Policy explains how Roumini Limited, a company registered in the Republic of Cyprus with registration number HE 402175 and registered office at Καλυψούς, 13, Floor 4, Flat/Office 402 Στρόβολος 2014, Λευκωσία, Κύπρος (“Company”, “we”, “us” or “our”), processes personal data collected through our website https://roumini.com/.

We provide IT consulting, management consulting, software development and related technology services.

1. Who we are
For the purposes described in this Privacy Policy, Roumini Ltd usually acts as the data controller. This means that we determine why and how your personal data is processed.

When we provide services to our clients, we may process personal data on behalf of a client under a data processing agreement. In those cases, the client is usually the data controller and we act as processor. If you have questions about personal data processed by one of our clients, please contact that client directly.

2. Contact details
Controller: Roumini Ltd
Registered office: Καλυψούς, 13, Floor 4, Flat/Office 402 Στρόβολος 2014, Λευκωσία, Κύπρος
Email: ceo@roumini.com

3. Scope of this Privacy Policy
This Privacy Policy applies only to personal data collected through our website contact form and to strictly necessary cookies used to operate the website.

We do not use the website to conduct marketing activities. We do not use website analytics cookies, advertising cookies, tracking cookies, social media tracking pixels or similar technologies.

We do not collect personal data through the website other than the information you choose to submit through the contact form.

4. Personal data we collect
When you submit the contact form on our website, we collect the following information:

• name;
• company name;
• email address;
• request text.

Please do not include sensitive personal data in the request text, such as health information, identification documents, financial information, political opinions, religious beliefs, trade union membership or other special category data, unless we specifically request it.

5. Why we use your personal data
We use the personal data submitted through the contact form only to:

• review your request;
• respond to your enquiry;
• communicate with you about your request;
• where relevant, take steps before entering into a contract with you or your company;
• keep appropriate business records of our communications.

We do not use contact form data for marketing, newsletter distribution, profiling, behavioral advertising or website analytics.

6. Legal basis for processing
We process contact form data on the following legal bases:

• Legitimate interests: to respond to business enquiries, manage communications and operate our business.
• Pre-contractual steps: where your request relates to a potential contract or services you are considering.
• Legal obligations: where we need to keep or disclose certain information to comply with applicable law.
• Legal claims: where processing is necessary to establish, exercise or defend legal claims.

Where we rely on legitimate interests, we consider whether our interests are overridden by your rights, freedoms and interests.

7. Cookies
Our website uses only strictly necessary cookies. These cookies are required for the website to function properly and cannot be used for analytics, advertising or tracking.

Strictly necessary cookies may be used for purposes such as website security, session management, form functionality or remembering technical choices required for the operation of the website.

Because we use only strictly necessary cookies, we do not ask for cookie consent on the website.

We do not use analytics cookies, marketing cookies, advertising cookies, social media tracking cookies or profiling technologies.

8. Who we share personal data with
We may share contact form data only where necessary with:

• our personnel who need access to respond to your request;
• IT, hosting, email and website service providers supporting our website and communications;
• professional advisers, such as lawyers, accountants or auditors, where necessary;
• public authorities, courts, regulators or law enforcement bodies where required by law or necessary to protect our rights.

Where service providers process personal data on our behalf, we require them to process it only under our instructions and to apply appropriate confidentiality and security measures.

We do not sell personal data.

9. International transfers
We are based in Cyprus, within the European Economic Area.

Some of our service providers may be located outside the European Economic Area or may process data from other countries. Where personal data is transferred outside the European Economic Area, we take steps to ensure an appropriate level of protection, such as relying on an adequacy decision, Standard Contractual Clauses or other safeguards permitted by applicable data protection law.

You may contact us for more information about the safeguards used for international transfers.

10. Retention
We keep contact form data only for as long as necessary to handle your request and maintain appropriate business records.

As a general rule, we retain contact form submissions for up to 12 months after the request is resolved, unless:

• a business relationship starts, in which case relevant communications may be retained as part of our business records;
• a longer period is required by law;
• the data is needed to establish, exercise or defend legal claims.

If a request leads to a business relationship, contract negotiations, a contract, a complaint, a dispute or a legal claim, we may retain the relevant communications for a longer period, where necessary, in accordance with applicable limitation periods and legal requirements. In such cases, relevant records may be retained for up to 6 years after the end of the relevant relationship, communication or matter, unless a longer period is required by law or necessary for legal claims.

When personal data is no longer needed, we delete it, anonymize it or securely archive it.

11. Security
We use appropriate technical and organizational measures to protect personal data against unauthorized or unlawful processing, accidental loss, destruction, damage, disclosure or access.

These measures may include access controls, secure hosting, confidentiality obligations, encrypted communications where appropriate, backups, vendor due diligence and internal access restrictions.

No website or electronic communication system is completely secure. If you believe that your communication with us is no longer secure, please contact us.

12. Your rights
Subject to applicable law and conditions, you may have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request deletion of your personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• request data portability, where applicable;
• withdraw consent, where processing is based on consent;
• lodge a complaint with a supervisory authority.

To exercise your rights, please contact us at ceo@roumini.com.

We may need to verify your identity before responding to your request.

13. Complaints
We encourage you to contact us first so that we can try to resolve your concern.

You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus or with another competent data protection authority in the EU Member State where you live, work or believe an infringement occurred.

14. Children
Our website and services are intended for business users and are not directed to children. We do not knowingly collect personal data from children through the website.

15. Automated decision-making
We do not use personal data collected through the website for automated decision-making, profiling, behavioral advertising or analytics.

16. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our processing activities, website or legal requirements.

The “Last updated” date at the top of this Privacy Policy indicates when it was last revised.

17. Contact us
If you have any questions about this Privacy Policy or how we process personal data, please contact:

Controller: Roumini Ltd
Registered office: Καλυψούς, 13, Floor 4, Flat/Office 402 Στρόβολος 2014, Λευκωσία, Κύπρος
Email: ceo@roumini.com