Privacy Policy

1. INTRODUCTION AND DATA CONTROLLER

This Privacy Policy describes how Vivameda Ltd ("Vivameda", "we", "us", or "our"), a company registered in Cyprus, collects, uses, discloses, and protects personal data when you visit our website, use our services, or when your professional data is included in our datasets.

Data Controller:
Vivameda Ltd
VAT: CY60189498Z
Lysis, Armou
8522 Paphos
Cyprus
Email: data@vivameda.com

We are committed to protecting privacy and ensuring compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679, the Cyprus Processing of Personal Data (Protection of the Individual) Law, and all other applicable data protection legislation.

2. NATURE OF OUR BUSINESS

B2B Data Infrastructure Company: Vivameda is a B2B data infrastructure company that provides structured workforce intelligence and company level analytical datasets for legitimate business purposes. Our datasets include:

• Company level headcount and growth metrics
• Role distributions and seniority classifications
• Workforce skill and capability signals
• Company affiliations and organizational data

Intended Use Cases

Our data products are designed exclusively for:

• AI Training and Research: Training machine learning models for identity resolution, workforce structure analysis, and organizational intelligence
• Market Intelligence: Business analysis, competitive research, and market sizing
• Historical Research: Time bounded historical snapshot analysis of organizational growth patterns and workforce composition trends

Not a Consumer Data Broker

Vivameda does not operate as a consumer data broker. We do not sell consumer behavioral data, personal financial information, health data, or any sensitive personal data categories as defined under GDPR Article 9. We do not sell personal data for direct marketing, prospecting, or unsolicited outreach purposes.

3. LEGAL BASIS FOR PROCESSING

We process personal data only when we have a lawful basis under Article 6 of the GDPR:

For Data Subjects in Our Datasets

• Legitimate Interests (Art. 6(1)(f)): Processing of publicly available professional data for B2B business intelligence, market research, and AI training purposes. We rely on legitimate interests under Art. 6(1)(f) GDPR and assess the impact of our processing on data subjects' rights and freedoms in accordance with applicable regulatory guidance, taking into account the professional and business context of the data.

For Website Visitors and Clients

• Contractual necessity (Art. 6(1)(b)): Processing necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract
• Legal obligation (Art. 6(1)(c)): Processing necessary for compliance with a legal obligation to which we are subject
• Consent (Art. 6(1)(a)): Where you have given explicit consent for specific processing activities

4. DATA SOURCES

Professional data in our datasets is obtained from:

• Publicly available professional networking platforms
• Public company websites and directories
• Licensed third party data providers
• Public business registries and filings
• Publicly accessible professional publications

We combine licensed third party sources with proprietary aggregation, normalization, and enrichment processes to create value added datasets.

We do not collect data through automated collection methods that violate applicable laws or platform terms of service. Data acquisition is performed via lawful, contractually permitted, and compliant collection methods.

5. PERSONAL DATA WE COLLECT

5.1 Data You Provide Directly (Clients and Visitors)

• Identity data: Name, job title, company name
• Contact data: Business email address, business phone number, company address
• Transaction data: Details of products and services purchased from us
• Communication data: Correspondence and communications with us
• Payment data: Payment details processed through secure third party payment processors

5.2 Data in Our B2B Datasets

• Company names and affiliations
• Aggregated headcount metrics and growth data
• Role distributions and seniority classifications
• Professional skills and competencies (aggregated)
• Geographic location (country, region, business context)
• Industry and sector classifications

5.3 Data Collected Automatically

• Technical data: IP address, browser type and version, time zone setting, browser plugin types and versions, operating system and platform
• Usage data: Information about how you use our website and services
• Device data: Device identifiers and characteristics

6. PURPOSES OF PROCESSING

For Our B2B Data Products

• AI model training for identity resolution and career path modeling
• Market intelligence and competitive analysis for enterprises
• Historical and statistical research on workforce trends
• Organizational structure analysis

For Website Visitors and Clients

• To perform and manage our contractual obligations with you
• To respond to your inquiries and provide customer support
• To process payments and prevent fraud
• To send administrative communications about our services
• To comply with legal and regulatory obligations
• To improve our website, services, and user experience

7. CLIENT OBLIGATIONS

Clients purchasing our data products agree to:

• Use data only for the permitted purposes specified in their agreement
• Not use data for unsolicited consumer marketing or spam
• Implement appropriate technical and organizational security measures
• Comply with all applicable data protection laws in their jurisdiction
• Honor data subject rights requests forwarded by Vivameda
• Not attempt to re-identify anonymized or aggregated data
• Sign appropriate Data Processing Agreements (DPAs) where required

Data Use Restriction

All data elements included in our datasets are provided exclusively for internal analytical and research purposes to support organizational and workforce intelligence.

Resale Prohibition: The resale, sublicensing, or redistribution of any data elements to third parties is strictly prohibited. This restriction is contractually binding and enforced through our Data Processing Agreements. Violation of this provision constitutes a material breach of contract and may result in immediate termination of data access.

8. DATA SHARING AND DISCLOSURE

We may share personal data with:

• Licensed clients: Business customers who have agreed to our terms and signed appropriate data protection agreements
• Service providers: Third party vendors who assist us in operating our business (e.g., payment processors, hosting providers, analytics services)
• Legal authorities: When required by law, court order, or governmental regulation
• Professional advisors: Lawyers, auditors, and consultants as necessary
• Business transfers: In connection with a merger, acquisition, or sale of assets

We require all third parties to respect the security of personal data and to treat it in accordance with the law.

9. INTERNATIONAL DATA TRANSFERS

As a company based in Cyprus (a member of the European Union), we primarily process data within the European Economic Area (EEA). Where we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, including:

• Transfers to countries with an EU adequacy decision
• Standard Contractual Clauses (SCCs) approved by the European Commission
• Binding Corporate Rules where applicable
• Other legally approved transfer mechanisms

10. DATA RETENTION

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected:

• B2B dataset records: Professional data is retained for as long as it remains accurate, relevant, and necessary for our stated purposes, and is typically reviewed on a 24 month cycle
• Client data: Duration of our business relationship plus any applicable statutory retention period
• Legal requirements: As required by applicable tax, accounting, and regulatory laws

When personal data is no longer required, we will securely delete or anonymize it.

11. YOUR RIGHTS UNDER GDPR

Under the General Data Protection Regulation, you have the following rights:

• Right of Access (Art. 15): You have the right to obtain confirmation as to whether personal data concerning you is being processed and, if so, access to that data
• Right to Rectification (Art. 16): You have the right to have inaccurate personal data corrected without undue delay
• Right to Erasure (Art. 17): You have the right to have your personal data erased in certain circumstances ("right to be forgotten")
• Right to Restriction (Art. 18): You have the right to restrict processing of your personal data in certain circumstances
• Right to Data Portability (Art. 20): You have the right to receive your personal data in a structured, commonly used, machine-readable format
• Right to Object (Art. 21): You have the right to object to processing based on legitimate interests. Where we process your data based on legitimate interests, you may object and we will cease processing unless we have compelling legitimate grounds
• Right to Withdraw Consent (Art. 7): Where processing is based on consent, you have the right to withdraw consent at any time

How to Exercise Your Rights: To exercise any of these rights, including to be removed from our datasets, please contact us at data@vivameda.com. We will respond to your request within one month, as required by law. We will also notify any clients who have received your data of your request where technically feasible.

12. RIGHT TO LODGE A COMPLAINT

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. For Cyprus, the competent authority is:

Office of the Commissioner for Personal Data Protection
1 Iasonos Street
1082 Nicosia
Cyprus
Tel: +357 22 818 456
Email: commissioner@dataprotection.gov.cy
Website: www.dataprotection.gov.cy

You may also lodge a complaint with the supervisory authority in your country of residence or place of work.

13. DATA SECURITY

We have implemented appropriate technical and organizational measures to protect personal data against:

• Unauthorized or unlawful processing
• Accidental loss, destruction, or damage
• Unauthorized disclosure or access

These measures include encryption, access controls, secure data storage in Tier 3 data centers (Helsinki, Finland), and regular security assessments. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

14. COOKIES AND TRACKING TECHNOLOGIES

Our website may use cookies and similar tracking technologies to enhance your browsing experience and analyze website usage. Categories of cookies we may use include:

• Strictly necessary cookies: Essential for website functionality
• Performance cookies: Help us understand how visitors use our website
• Functional cookies: Enable enhanced functionality and personalization

You can control cookie settings through your browser. Disabling certain cookies may affect website functionality.

15. CHILDREN'S PRIVACY

Our services are intended for business professionals and are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child, we will take steps to delete that information promptly.

16. AUTOMATED DECISION MAKING

Vivameda does not use personal data to make automated decisions that produce legal or similarly significant effects on individuals.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. Material changes will be communicated through:

• A prominent notice on our website
• Direct communication where appropriate
• Updating the "Last updated" date at the top of this policy

We encourage you to review this Privacy Policy periodically.

18. CONTACT US

For any questions, concerns, or requests regarding this Privacy Policy, our data processing practices, or to exercise your data subject rights, please contact us:

We aim to respond to all legitimate requests within one month. Occasionally it may take longer if your request is particularly complex or you have made multiple requests.