We value the trust you place in us and to this respect we are committed to protecting your privacy.
Personal Data we collect
The personal data that we may collect includes:
- Basic information: such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
- Contact information: such as your postal address, business address, residential address email address, telephone number, mobile number and fax number(s);
- Financial information: such as income, expenditure, sources of wealth, as well as your bank account details which we are required to have for compliance purposes;
- Compliance, Identification and background information: provided by you or collected as part of our business acceptance processes and legal due diligence/know your clients obligations which we are required to implement. This may include information such as your education, tax identification number, passport or national identity card details, country of domicile and/or your nationality. In addition we may collect details relevant to international sanctions and restrictive measures and any other information in order to assess whether you are a politically exposed person or money laundering risk; and
- Publicly available information:Information collected from publicly available resources, including but not limited to information collected from databases we use to carry out compliance screening or credit rating agencies.
Collection of your Personal Data
We may collect personal data from you:
- In the course of our business and contractual obligations;
- In order to comply with the legal and regulatory obligations;
- When you or your company seek our legal, fiduciary, corporate and/or other services;
- When you or your company contact and/or request information from us through our website, in person, over email or over the telephone. We may monitor, record and store any such communication;
- When you or your company provide services to us, or otherwise offer to do so; and
- We may collect or receive information about you from publicly available sources or from third parties, most commonly where we need to conduct background checks about you.
We may also collect personal data from your agent, adviser and intermediary for the purpose of providing the requested services to you.
How we use your Personal Data
We will use your personal data for the following defined purposes:
- To perform the contract we are to enter into or have entered into with you or your company;
- To provide the legal, corporate, fiduciary or any other services you have requested;
- To manage and administer our relationship with you or your company (this is not limited to but includes accounting, auditing, and any other services);
- In order to fulfil and comply with our legal and regulatory obligations related anti-money laundering, terrorist finance. This also includes reporting to and/or being inspected and/or audited by national and international regulatory, law enforcement and government bodies;
- Upon your instruction or request from your company, agent, advisor, intermediary or other relevant third party entity;
- If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings; and
- To analyse and improve the services we provide you with.
Disclosure of your personal data
We may have to share your personal data with:
- Our professional advisors/service providers where it is necessary for us to obtain their advice or professional assistance such as tax advisors and auditors;
- Our IT Service Providers and Data Storage Providers;
- Any third party to whom we assign or novate any of our rights or obligations;
- Companies providing services for the purposes of the legally required compliance checks, as well as companies providing similar services including financial institutions;
- Third parties with whom we engage in delivering services to you;
Relevant regulatory authorities, courts, government bodies and law enforcement agencies when we are required to do so in accordance with any applicable law, regulation, judicial or official request to do so.
We will obtain your prior specific consent before we share your personal data or data to any third party for any purpose that is not directly connected with the provision of our services.
Legal Grounds we Use Processing of your Personal Data
We will only collect and process personal data about you where we have the legal basis in accordance with the data protection regulations, such as:
- consent (where you have given consent for one or more specific purpose);
- contract (where processing is necessary for the performance of a contract); and
- where there is a legitimate interest.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal, and, where we rely on legitimate interests, we shall specify the legitimate interests pursued by the controller or by a third party and you have the right to object.
Security of your Personal Data
We use a range of physical, technical and organizational measures to keep your personal data secure and confidential.
International Transfers of your Personal Data
In order to provide our services, we may need to transfer your personal data to jurisdictions outside the European Union. In this case, we will implement the appropriate measures so as to ensure that your personal data remains protected and that the recipient has entered into European Commission standard contractual clauses with us.
How long do we keep your personal data?
We will only retain your personal data for as long as it is reasonably necessary to do so and in order to provide the requested services to you, or, where we have relied on your consent to keep your personal data, once you withdraw your consent for us to do so, and we are not otherwise legally permitted or required to keep the data. This also includes the purposes of satisfying any legal, accounting, compliance or reporting obligations.
Access and Control Your Personal Data
You have the right to access, correct or delete your personal data, as follows:
Delete data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you or if you withdraw you consent), by sending us an email.
Change or correct data: You can ask us to change, update or amend your personal data in certain cases, particularly if it's inaccurate, by sending us an email. We must ensure that your personal information is accurate and up to date. To this respect please advise us of any changes to your personal data by emailing us at firstname.lastname@example.org
Object to, or limit or restrict, use of data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to access and/or take your data: You can ask us for a copy of your personal data and a copy of personal data you provided in machine readable form. If you wish to exercise any of the rights set out above, please contact us at email@example.com. When you contact us we may request specific information from you in order to enable us to confirm your identity and protect the personal data we hold from unauthorised access requests.
We may charge you a reasonable administrative fee for any unreasonable, unfounded, repetitive requests we may receive, and for any additional copies of the data you may request.
If you are not satisfied with how we manage your personal data, you have the right to make a complaint to the data protection authority in Cyprus at www.dataprotection.gov.cy. A list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
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Get in touch
Please feel free to contact us with any questions, comments or clarifications you may have at firstname.lastname@example.org.