Home About Us Services Jurisdictions Jobs Contact Us Privacy Policy This Privacy Policy is given in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regards to the processing of personal data and the free movement of such data (the “GDPR”), the Cyprus Law 125(I)/2018 providing for the protection of natural persons with regard to the processing of personal data and for the free movement of such data as well as any applicable laws in the Republic of Cyprus. Any reference to “us”, “we” or “our” is reference to Feldmans Management (Overseas) Limited and/or its subsidiaries and/or its officers and/or its employees. Any reference to “you” or “your” is reference to any natural or legal person dealing with us in any capacity whatsoever. This page informs you of our policies regarding the collection, storage, use, processing and disclosure of your Personal Data Information and your rights in relation to your Personal Data Information. We will not collect, store, use, process or share your Personal Data Information with anyone except as described in this Privacy Policy or as applicable by effective legislation of the Republic of Cyprus or the European Union. The Personal Data Information we collect about you “Personal Data Information” means any information about you that could identify you directly or indirectly. This information may include, but is not limited to, your personal information, contact information, business information, financial information, background information and payment details. We may also create Personal Data Information about you, for example, records of your communications and interactions with us. Apart from the above, we may also collect information that your browser sends whenever you visit our website (“Log Data”). By using our website, you agree to the collection and processing of such information in accordance with this Privacy Policy. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics. We note that we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our website’s functionality. These third party service providers have their own privacy policies addressing how they use such information. How your Personal Data Information is collected We may collect or obtain your Personal Data Information directly from you and/or third parties acting as your agents, employees or representatives or in any other capacity and/or when you and/or the aforementioned third parties send us information through our website and/or in the course of our business relationship with you and/or when you and/or the aforementioned third parties seek advice or other services from us and/or through screening providers and/or from public records and sources and/or from law enforcement authorities. Why we collect your Personal Data Information and how we use it “Processing” means any operation or set of operations performed on your Personal Data Information, by automated means or otherwise, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. We will process your Personal Data Information for the purposes of providing our services to you and/or entering into a contract with you and/or managing and administrating our relationship with you and/or communicating and/or interacting with you and/or understanding and responding to your inquiries and/or confirming and verifying your identity and/or completing client compliance checks and/or complying with our legal and regulatory obligations under any applicable laws as well as guidelines issued by the relevant regulator for our activities and/or establishing and/or exercising legal rights or claims and/or conducting fraud or other criminal investigations and/or managing and administrating the fulfilment of your or our financial obligations and/or managing our IT and security systems and/or pursuing any other legitimate business interest we may have provided that this does not override any interests or fundamental rights and freedoms you have as an individual. We seek to ensure that your Personal Data Information that we process is limited to what is necessary for the purposes set out in this Privacy Policy. Recipients of your Personal Data Information Your Personal Data Information will be kept confidential by us and will not be disclosed or made known to third parties, except as may be required and/or deemed necessary for the provision of our services and/or when you direct us or give us permission and/or when we are required by applicable law or regulations or judicial or official request to do so and/or when we exercise or defend a legal claim and/or when such disclosure is required for conducting fraud or other criminal investigations. Service Providers We may employ third party companies and individuals to facilitate our website, to provide the website on our behalf, to perform website-related services or to assist us in analyzing how our website is used. These third parties have access to your Personal Data Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Storage of your Personal Data Information We will retain your Personal Data Information only for the period of time we are engaged to provide services to you and/or for as long as necessary to fulfil the purposes we collected it for and/or for a longer period if this is necessary for the purposes of satisfying any legal, accounting or regulatory requirements. In determining the appropriate retention period for your Personal Data Information, we take into account, inter alia, the nature of the data, the purposes for which we process them and whether we can achieve those purposes through other means as well as the potential risk of harm from unauthorized use. We note that your Personal Data Information may be kept on our IT systems and/or in paper files. Personal Data Information about other people In case you provide us with Personal Data Information of other people such us your clients, directors, shareholders, beneficial owners or employees, you must ensure that you are entitled to disclose that information to us and that, we may collect, store process and disclose it as described in this Privacy Policy, without taking any further steps. The individual concerned must be aware of the content of this Privacy Policy. Cookies Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website. Security The security of your Personal Data Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data Information and prevent it from being accidentally accessed, lost, disclosed and or used in an unauthorized way, we cannot guarantee its absolute security. We limit access to your Personal Data Information to people having a genuine business need to have access to it and those people will process your Personal Data Information only in an authorized manner and will be bound by confidentiality obligations. Links to other sites Our website, email updates and other communications may contain links to and from other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. We strongly advise you to review the privacy policy of every website you visit, noting that the personal data that you provide through these websites are not subject to this Privacy Policy. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party websites or services. Children’s Privacy Our website does not address anyone under the age of 14 (“Children”). We do not knowingly collect personally identifiable information from children under 14. If you are a parent or guardian and you are aware that your children have provided us with Personal Data Information, please contact us. If we become aware that we have collected Personal Data Information from a child under age 14 without verification of parental consent, we take steps to remove that information from our servers. Your rights Request Access: you are entitled to ask us if we are processing your Personal Data Information and, if we are, you are entitled to request and receive a copy of this information we hold about you free of charge. Request Correction: you are entitled to request that any Personal Data Information we hold about you is corrected if inaccurate or incomplete. However, we may need to verify the accuracy of the new Personal Data Information you provide to us. Request Erasure: you are entitled to request that any Personal Data Information we hold about you is deleted and/or removed (the right to be forgotten). However, we may deny the erasure if the processing is necessary for compliance with legal requirements and/or obligations and/or for the establishment, exercise or defense of legal claims. Right to object to or restrict the processing of your Personal Data Information: you have the right to object to the processing of your Personal Data Information or ask us to suspend such processing provided that we do not have compelling legitimate grounds to process such information which override your rights and freedoms. Right to data portability: you are entitled to request the transmission of your Personal Data Information collected from us to another party. Right to object to automated decision-making: you have the right to object to decisions being taken by automated means producing legal effects concerning you or similarly significantly affect you (including profiling). Right to lodge a complaint: if you consider that the processing of your Personal Data Information infringes the provisions of the applicable legislation, you are entitled to file a complaint at the Commissioner of Personal Data Protection. For more information regarding the process, please visit the website www.dataprotection.gov.cy. Right to withdraw consent: in case we are processing your Personal Data Information with consent, you are entitled to withdraw your consent at any time by contacting us. We will stop processing your Personal Data Information and we will erasure such information unless this information is necessary for compliance with applicable law. We note that the withdrawal of your consent will not affect the lawfulness of the processing based on your consent before the withdrawal. Changes to this Privacy Policy This Privacy Policy was last updated in April 2020. We may update our Privacy Policy from time to time to reflect changing legal requirements or change in our practices. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Contact Us If you have any questions in relation to this Privacy Policy or the use of your Personal Data Information by us or you wish to exercise your rights, please contact our appointed data protection officer at: Address: Efterpis 1, 2003, Strovolos, Nicosia Telephone: + 357 22 873 860 Email: info@feldmans.com.cy Please note that we may require proof of your identity before we can give effect to your rights. SEARCH Home About Us Services Jurisdictions Privacy Policy Contact Us © 2021 Feldmans Management (Overseas) Limited | Disclaimer