Last Modified Date: 1st of December 2018
S. CONSTANTINOU & ASSOCIATES LLC
Our Privacy and Data Compliance Officer’s contact details are:
Email – [email protected]
Telephone no. – +357 22 42 11 90
Under the GDPR you have the following rights:
- To instruct us to cease processing your personal data if the processing is causing you damage or distress;
- To gain access to, and copies of, the personal data that we hold about you;
- To instruct us not to send you marketing communications;
- To instruct us to restrict our data processing activities;
- To instruct us to erase your personal data;
- To obtain from us the personal data we hold about you which you have provided to us, in a practical format specified by you, including for the purpose of you transmitting that personal data to another data controller;
- To instruct us to correct the personal data we hold about you if it is incorrect.
Please note that the above rights are not absolute, and we may be titled to refuse requests where exceptions apply.
You may find out more about your rights at the website of the Office of the Commissioner for Personal Data Protection at www.dataprotection.gov.cy or by contacting us.
If you are not satisfied with how we are processing your personal data, you can make a complaint to www.dataprotection.gov.cy .
How we collect your data
We collect your personal data in multiple ways, for example:
- From the material you provide to us when you meet us;
- When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
- When you complete (or we complete on your behalf) client engagement forms or any other forms;
- From other affiliated companies of ours;
- From your agents, advisers and intermediaries;
- From publicly available sources or from third parties.
The categories of personal data we collect
We collect the following categories of personal data about you through our Website:
- Your name and contact information such as your home or business address, email address and telephone and fax number;
- Biographical information which may confirm your identity including your date of birth, tax identification number, VAT number, reference letters, CV, ARC, passport number, driver’s license or national identity card details, country of domicile and/or your nationality;
- Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;
- An understanding of your goals and objectives in our services;
- Information to assess whether you may be characterized as a politically exposed person or a person involved in terrorist financing/ money laundering.
- Information that you provide by filling in forms, in particular at the time of first contact with us.
- We also collect Personal Information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
- Details of transactions you carry out, if any, and of the fulfillment of your orders.
The rationale behind the processing of your personal data (other than with your consent), the use of that personal data and whom we share it with:
(i) Performance of a contract with you
We process your personal data in the course of the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
In this respect, we use your personal data for the following:
- To prepare a quotation for you in respect to the services we offer;
- To provide you with the services as set out in our Engagement Letter with you or as otherwise agreed with you from time to time;
- To deal with any complaints or feedback you may have;
- For any other purpose for which you provide us with your personal data. In this respect, we may share your personal data with or transfer it to the following:
- Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
- Third parties whom we engage to assist in delivering the services to you, including our affiliated companies;
- Our professional consultants where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, or IT;
- Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
- Our data storage providers.
(ii) Legal obligations
We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:
- To meet our compliance and regulatory obligations, such as compliance with anti-money laundering and anti- terrorist financing laws;
- As required by tax authorities or any competent court or legal authority. In this respect, we will share your personal data with the following:
- Our consultants where it is necessary for us to obtain their advice or assistance;
- Our auditors where it is necessary as part of their auditing functions;
- With relevant regulators or law enforcement agencies where we are required to do so.
(iii) Legitimate interests
We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.
In this respect, we use your personal data for the following:For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis; Seeking advice on our rights and obligations, such as where we require our own legal advice;
In this respect we will share your personal data with the following:
- Our advisers or agents where it is necessary for us to obtain their advice or support; With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
We may send you marketing information about similar services we provide, as well as other information in the form of e-mails and invitations to events which we believe might be of interest to you.
We may communicate this to you in a number of ways including by telephone or email.
If you object to receiving marketing from us at any time, please contact us:
- By email – [email protected]
Transfer and processing of your personal data outside the European Union
- the country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;
- the transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
- when you have explicitly consented to the same.
Retention of your data
Where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for five years after the termination of our business relationship, unless we are required to retain this information by another law or for the purposes of court proceedings.
No Rights of Third Parties
No Error Free Performance