Privacy Policy


  • Medcom Trading LTD, a company duly incorporated in the Republic of Cyprus, under Registration Number HE273762, hereinafter referred to as the Company, is based in the Republic of Cyprus and provides consulting, business development, trade management, cruise lines supply and financing services and is engaged in trade in Africa, hereinafter referred to as the Services.


  • This Privacy Policy outlines how the Company, manages and protects personal data and/or information which is collected by the Company and/or is provided by the Customers of the Company throughout and in connection with the Services and/or Users of, the Company’s Website, hereinafter collectively referred to as the Customers.


  • The data and/or information of the Customers collected by the Company varies depending on the services provided or to be provided by the Company to the Customers, and/or the use of the Website by the Customers, as follows:


  1. a) Through and throughout the Customer’s use of the Website. Every time a Customer accesses, views and browses and/or uses the Website, the Customer signifies acceptance of the effective Privacy Policy and provides consent to the management and processing of any data displayed, transferred through or uploaded to the Website, which does not include personal data of the Customer. If the Customer does not accept the Privacy Policy, then the Customer is not authorized to use the Website and must immediately cease use of the Website.


  1. b) Through any documents submitted and/or provided by the Customers to the Company regarding or in connection to the provision of the Services by the Company.


  1. c) Throughout any form of communication held between the Company and the Customer, including telephone, email and post.


  • Throughout the Company’s relationship with the Customers, the Company may collect the following personal data/information of the Customer:


  1. a) Name, Surname, Residential Address, E-mail, and Telephone Number


  1. b) Banking information, including account number, card information and payment details


  1. c) Data and/or information in connection with the Customer’s services provided by the Company


  1. d) Data and/or information regarding and throughout the Customer’s use of the Company’s Website, including browsing and location data.


  • The Company may collect information about the Customer’s activity on the websites via use of tracking technologies such as cookies and other non-personal information such as the Customer’s IP address and content accessed by the Customer throughout use of the Company’s website.


  • The Company may use the data/information collected as follows:


  1. a) For the purposes of provision of the Services by the Company


  1. b) For the purposes of receiving payments from Customers and providing them with invoices, statements and/or reminders relevant to or in connection with the Services.


  1. c) For the purposes of responding to any of the Customers inquiries and/or requests.


  1. d) For the purposes of identifying, preventing and detecting fraud, impersonation or any other unlawful acts.


  1. e) For the purposes of collecting and/or receiving any dues by and/from the Company’s Customers.




  • The Company may collect, process or manage personal information of the Customer, by obtaining the consent of the Customer to the same. Every time the Customer requests the Company to provide its Services to the Customer, the Customer must provide such consent to the Company, by actively agreeing to be bound by the Privacy Policy, (positive opt-in) the moment the Customer proceeds to contact and/or communicate with the Company through the Website, with regards to the provision of the Services by the Company as well as at the moment that the Customer proceeds to convey and/or upload any information and/or data, including personal data, through the Website to the Company.
  • The Company processes the personal data/information of the Customers in line with the relevant domestic data protection laws, as well as the EU General Data Protection Regulation.
  • This data/information is processed for the purposes of effectively providing the Company’s Services to Customers, to implement the Company’s contractual obligations, to protect and secure the Company’s Customers, and to protect the Company’s interests.


  • The Company may use and/or process personal data/information based on any of the following reasons:


  1. a) The effective provision of the Services by the Company to the Customers, pursuant to relevant agreements concluded between them or otherwise.


  1. b) The Company’s compliance with any law and/or regulation.


  1. c) The provided Customer’s consent. The Customer may cancel and/or revoke such consent.
  1. d) The protection of the legitimate interests of the Company, such as updating and improving the Company’s Services and prevent possibilities of fraud or other unlawful acts.


  1. e) There is a lawful basis for the Company to do so.


  1. f) The Company may use or share such information with any partners and/or counterparties of the Company and with any third parties if this is necessary or required in order for the Company to effectively provide its Services to the Customer.


  • The Company pursues to allow its Customers to have better control over their data and aims to be at all times in line with the General Data Protection Regulation (GDPR). The Customer always has the right, with regards to its data kept by the Company, to be informed with regards to the processing of such data, to amend or update any data that may be inaccurate, incomplete or incorrect, to erase or delete any such data, to restrict the processing of the data and to access the data upon such request. Following the submission, transmission, upload or otherwise provision of personal information to the Company by the Customer, if such information changes at any time, the Customer may delete, update, review or alter personal information by providing the Company with an email requesting the same. The Company shall use its best endeavours to undertake such requests as soon as possible.


  • The Company may use or share data/information with any partners and/or counterparties of the Company and with any third parties if this is necessary or required in order for the Company to effectively provide its Services to the Customer.
  • The Company may further disclose the Customer’s personal information and/or data to third parties, if the Company believes that such third parties need to contact the Customer, without limitation, for the following purposes:


  1. a) The Company is required to do so by law or Court proceedings


  1. b) The Company is required to do so by governmental departments or law enforcement authorities


  1. c) The Company deems in good faith that it is advisable or necessary to provide its Services


Any information/data, whether personal or not, which is posted, transferred through or displayed on the Website by the Company, may not be used or copied in any manner or form without the written consent of the Company.



The Website of the Company may provide or display links to other websites of third party physical or legal entities. While displaying or providing such links, the Company does not endorse, control or operate them, disclaims any liability or responsibility for the content of such websites and use of such websites are at the sole discretion and responsibility of the Customer, including without limitation, such websites’ privacy policies.


The Company does not make any representations or warranties that the Company’s website or any third party websites for which the links are provided or displayed on the Company’s website shall function properly, without any interruptions or errors or that they are free of viruses or other issues which may harm the Customer’s computer.



The Company has in place certain procedures in pursuit of safeguarding and securing the information which is transmitted, collected online and/or is otherwise collected by the Company. The Company protects such information, including personal information by undertaking reasonable precautions and following the industries best practices to make sure that such data is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.


Any Customer may contact the Company at any time, for any clarifications with regards to the type of data kept by the Company, and with regards to accessing, rectifying, erasing and/or restricting that Customer’s personal data.


  • The Company may revise the Privacy Policy from time to time and provide or display an effective date of the revised Privacy Policy on the Website. Any revisions and alterations of the Privacy Policy shall be effective as of the date on which the revised or altered Privacy Policy is posted or otherwise made available on the Website of the Company. The Customer should monitor the Privacy Policy on a regular basis in order to be aware of the most recent applicable Privacy Policy. The Privacy Policy is effective as of the 25th day of May 2018.