Last updated: 08.01.2026
1. Data Controller
The data controller within the meaning of Regulation (EU) 2016/679 (GDPR) is:
Company name: Cine-Books Entertainment Ltd
Legal form: Ltd
Registered address: 1, Arhciepiskopou Makariou III, Mitsis Building No.3, Office 310, 1065, Nicosia, Cyprus
Email: ![]()
2. Scope of This Privacy Policy
This Privacy Policy applies to the website cinearty.com (the “Website”) and to all personal data processed in connection with the sale of goods to consumers within the European Union.
3. Personal Data We Process
3.1 Customer account and order data
- First and last name
- Billing and delivery address
- Email address
- Telephone number (not required)
- Company Name (not required)
- User account credentials (hashed passwords)
- Order history and order details
- Payment status and transaction references. We do not store full payment card details.
3.2 Newsletter and marketing data
- Email address
- Subscription status and consent records
- Interaction with marketing emails (opens, clicks)
3.3 Automatically collected data
- IP address
- Device, browser, and operating system information
- Website usage data
- Cookies and similar technologies
4. Purposes and Legal Basis of Processing
| Purpose | Legal Basis (GDPR Art. 6) |
|---|---|
| Customer account management | Contract (Art. 6(1)(b)) |
| Order processing and delivery | Contract (Art. 6(1)(b)) |
| Customer support | Contract (Art. 6(1)(b)) |
| Accounting and tax compliance | Legal obligation (Art. 6(1)(c)) |
| Newsletter subscription | Consent (Art. 6(1)(a)) |
| Abandoned cart notifications | Legitimate interest (Art. 6(1)(f)) |
| Website analytics (GA4) | Consent (Art. 6(1)(a)) |
| Website security and performance | Legitimate interest (Art. 6(1)(f)) |
5. Newsletter and Marketing Communications
Users may voluntarily subscribe to our newsletter. Subscription is based on explicit opt-in consent.
Users may unsubscribe at any time by using the unsubscribe link in each email or by contacting us directly.
6. Abandoned Cart Notifications
If a user initiates an order but does not complete checkout, we may send reminder emails regarding the abandoned cart.
This processing is based on our legitimate interest in completing the transaction.
Users may opt out of such notifications at any time.
7. Google Analytics (GA4)
We use Google Analytics 4 (GA4), provided by Google Ireland Limited, to analyze website usage.
- GA4 is activated only after consent via the cookie banner
- IP anonymization is enabled where applicable
- Data may be transferred to servers outside the EU under appropriate safeguards
More information: https://policies.google.com/privacy
8. E-commerce Platform and CDN
Our Website is operated using BigCommerce, which provides:
- Hosting and infrastructure
- Order management and customer accounts
- Image caching and content delivery via CDN
The CDN may technically process IP addresses and device information for performance and security purposes. Such processing is limited, necessary, and conducted under GDPR-compliant Data Processing Agreements.
9. Service Providers (Processors)
We share personal data only with service providers strictly necessary for business operations:
- E-commerce platform provider (BigCommerce)
- Payment service providers
- Shipping and logistics partners
- Analytics provider (Google Analytics)
All processors act under contractual obligations in accordance with GDPR Art. 28.
10. International Data Transfers
Where personal data is transferred outside the EEA, such transfers are protected by:
- European Commission adequacy decisions, or
- Standard Contractual Clauses (SCCs)
11. Data Retention
Personal data is retained only for as long as necessary:
- Customer account data: until account deletion
- Order and accounting data: according to Cypriot legal retention requirements
- Marketing data: until consent withdrawal
- Analytics data: per GA4 retention settings
- Server logs: limited period for security purposes
12. Cookies
We use cookies for:
- Essential website functionality
- Analytics and performance (subject to consent)
Non-essential cookies are set only after explicit user consent.
Users may manage cookie preferences at any time.
13. Data Subject Rights
Users have the following rights under GDPR:
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction
- Right to data portability
- Right to object
- Right to withdraw consent at any time
Requests can be sent to: ![]()

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