Privacy Policy

Last updated: 8 October 2026

R3NEW Holding Ltd. respects your privacy and is committed to protecting personal data in accordance with the General Data Protection Regulation (“GDPR”) and applicable European Union laws.

This Privacy Policy applies to our informational website, which provides background information about R3NEW Holding Ltd. for potential investors, business partners, and the general public.

1. Data Controller

The controller responsible for processing personal data on this website is:

R3NEW Holding Ltd.
Represented by Director: Thomas Graetz
6 Emmanouil Roidi
1095 Nicosia, Cyprus
Registration Number: HE 477499
VAT ID: CY60182888L
Email: info@r3new-holding.com

2. Server Logs and Technical Data

When you access our website, technical data necessary to deliver and secure the website is automatically processed by our web servers. This may include:

• IP address
• Date and time of access
• Browser type, language, and operating system
• Requested web pages or resources

Purpose and legal basis: We process this information solely to maintain the stability, performance, and security of our website. The legal basis is Art. 6(1)(f) GDPR (our legitimate interest in operating a secure and reliable online presence).

3. Cookies and Analytics

• We do not use tracking cookies, web analytics tools, advertising pixels, or marketing trackers.
• We do not collect personal data to profile visitors or serve tailored advertisements.

If essential technical cookies are required to maintain basic site navigation, they are processed based on Art. 6(1)(f) GDPR.

4. Contact Enquiries

If you reach out to us by email or another communication channel, we process the information you provide, which may include:

• Name and contact details (email address, phone number)
• Company or organization name
• The content of your inquiry or message

Purpose and legal basis: We process this data to handle your inquiry, evaluate potential partnership or investment opportunities, and manage ongoing correspondence.

• Art. 6(1)(f) GDPR (our legitimate interest in conducting business communications).
• Art. 6(1)(b) GDPR (where processing is necessary prior to entering into a potential agreement).

5. Recipients and Third-Party Providers

We do not sell, rent, or trade your personal data. Personal data may only be accessed by or shared with:

• IT Infrastructure Providers: Hosting, domain, and web security providers needed to run our site.
• Professional Advisers: Legal, tax, or accounting advisers, where strictly necessary.
• Public Authorities: Only where required by EU or Cyprus law.

6. International Data Transfers

If any IT or cloud providers process data outside the European Economic Area (EEA), such transfers are conducted under recognized GDPR safeguard mechanisms pursuant to Art. 44 et seq. GDPR, including European Commission Adequacy Decisions or standard contractual clauses.

7. Data Retention

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

• General Enquiries: Retained for the duration of our correspondence and reasonable follow-up.
• Statutory Obligations: Retained longer where required by applicable Cyprus corporate or tax law.

8. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (“Right to be forgotten”) (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object to processing based on legitimate interests (Art. 21 GDPR)

To exercise any of these rights, contact us at info@r3new-holding.com.

9. Supervisory Authority

You have the right to lodge a complaint with the competent data protection supervisory authority. In Cyprus, this is:

Office of the Commissioner for Personal Data Protection
15 Kypranoros Street, 1061 Nicosia, Cyprus / P.O. Box 23378, 1682 Nicosia, Cyprus
Website: http://www.dataprotection.gov.cy

You may also contact the local supervisory authority in your EU Member State of habitual residence or place of work.