PERSONAL DATA CONTROLLER

The Company acts as the Data Controller of the personal data you provide. In this capacity, we are responsible for determining the purposes for which your personal data is processed and the means by which it is processed. As the Data Controller, we are committed to ensuring that all data processing activities are conducted in a lawful, fair, and transparent manner, in accordance with applicable data protection laws and regulations.

We take our responsibilities seriously and implement appropriate measures to safeguard your personal data throughout its lifecycle. This includes adhering to the principles of data minimization, accuracy, and accountability.

If you have any inquiries or concerns regarding your personal data or this Policy, please do not hesitate to reach out to us using the contact information provided above. Our team is here to assist you and ensure that your data protection rights are upheld.

CATEGORIES OF DATA COLLECTED

We collect various types of personal data for the purposes outlined in this Policy. The main categories of personal data we process include:

Contact Information: This includes your email addresses, phone numbers, and mailing addresses, and other information that allows us to communicate with you and provide customer support.
Regulatory Compliance Data: Information required to meet legal obligations, including Anti-Money Laundering (AML) screenings, Politically Exposed Persons (PEP) checks, and adherence to international sanctions.
Identity Information: This comprises your full name, identification numbers, details from official documents, and other information necessary for verifying your identity.
Technical Data: Information collected from the devices and technologies you use to access our services, such as IP addresses, browser specifications, and operating system details.
Professional Data: Details related to your job, such as your current position, the name of your employer, your professional accomplishments, and information related to your representation of a company or any authoritative roles you hold.
Risk and Fraud Assessment Information: Data on your business associations and affiliations that assists in evaluating risks and preventing fraud.
Communication Records: Records of communications, including phone calls, emails, and other channels, along with related metadata, to ensure quality service and support.
Data on Employment and Referrals: Information from job applicants and referrals, including CVs, employment history, educational background, and professional references, which is used for recruitment and staffing purposes.
Security Surveillance Information: Video recordings and associated metadata from our premises to maintain security and safety.

PURPOSES AND LEGAL GROUNDS FOR DATA PROCESSING

Our processing of personal data is conducted for specific and legitimate purposes, as outlined below, each accompanied by the corresponding legal grounds to ensure compliance with applicable laws:

Service Provision: This includes finalizing agreements, fulfilling contractual commitments, and delivering the requested services. Legal Basis: Contractual necessity.
Fulfillment of Contractual Obligations: This involves honoring contractual duties, executing agreed-upon actions, and preventing breaches of contract terms. Legal Basis: Contractual necessity and legal obligations.
Compliance with Legal and Regulatory Requirements: This encompasses adherence to applicable laws and regulatory standards, including anti-money laundering (AML) regulations, sanctions, risk management protocols, and tax/financial compliance obligations. Legal Basis: Compliance with legal obligations, public task.
Communication and Response to Inquiries: This involves engaging in communication with our users or customers, addressing their inquiries, and keeping them informed about our services. Legal Basis: Contractual necessity, compliance with legal obligations, and legitimate interests.
Marketing and Promotional Activities: This includes sending marketing materials and updates regarding our services that may be of interest to existing or potential customers. Legal Basis: Consent of the data subjects and legitimate interests.
Service and Operational Improvements: This entails enhancing the quality of our services and operational efficiencies, thereby improving the overall experience for our users and customers. br/> Legal Basis: Legitimate interests.
Recruitment and Employment: This includes conducting recruitment activities, whether directly or through referral programs, and making decisions regarding employment offers and contracts with potential employees. Legal Basis: Contractual necessity, consent of the data subjects, and legitimate interests. Management of Legal Disputes: This pertains to managing, establishing, or defending against legal claims in the event of disputes involving data subjects. Legal Basis: Legitimate interests.

We ensure that all data processing activities are carried out in a lawful, fair, and transparent manner, aligned with our commitment to uphold the highest standards of data protection. If you have any questions regarding the purposes and legal bases for our data processing, please contact us using the information provided above.

METHODS OF DATA COLLECTION

We collect personal data directly from you whenever you interact with us, such as when you use our services, contact us, or participate in our activities. Additionally, we may gather data from indirect sources, including third-party service providers, state authorities, and publicly available sources. This comprehensive approach ensures that we have accurate and up-to-date information to provide you with the best possible service.

MANDATORY AND OPTIONAL DATA

Certain data is essential for the use of our services, and failing to provide this data may restrict your access to these services. Optional data can be provided at your discretion and does not affect your access. We will clearly indicate when the provision of data is mandatory.

DATA SHARING

We share your personal data exclusively with trusted partners and service providers to ensure the effective delivery of our services. These partners are carefully selected and bound by contractual obligations to protect your data and use it only for the purposes specified by us. Additionally, we may share your data with state authorities when legally required to comply with applicable laws and regulations. We take all necessary steps to ensure that your data is handled securely and in accordance with this Privacy Policy.

DATA RETENTION

We retain personal data for as long as necessary to fulfill our obligations and serve you better. Personal data is retained for the duration of your active use of our services. To comply with legal and regulatory requirements, such as Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulations, data is typically retained for a minimum of five years. Data based on your consent is retained until such consent is withdrawn, after which it is securely deleted or anonymized unless required for other lawful purposes. For contractual obligations, data is retained for the duration of the contract and for an additional period, usually up to seven years. Data related to disputes and claims is retained until such matters are fully resolved. The retention period for these cases is determined by us and is generally aligned with the statutory limitation period for claims against us, typically up to ten years. We periodically review the data we hold to ensure its accuracy and necessity. When data is no longer needed, we securely delete or anonymize it.

INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries outside the European Union (EU) and the European Economic Area (EEA) in order to provide our services. To ensure the protection of your data, we implement appropriate safeguards. These safeguards include transferring data to countries that the European Commission has deemed to provide an adequate level of data protection through adequacy decisions. Furthermore, we utilize Standard Contractual Clauses (SCCs) approved by the European Commission to ensure that your data is afforded the necessary protection in accordance with EU standards. For further information regarding our international data transfer practices, please contact us using the provided contact information.

YOUR RIGHTS UNDER GDPR

We are committed to upholding your rights under the General Data Protection Regulation (GDPR). You have the following rights:

Right to Access: Request access to personal data we hold about you.
Right to Rectification: Request correction or update of incorrect or incomplete data.
Right to Erasure: Request deletion of data no longer necessary for its original purpose or if consent is withdrawn.
Right to Restrict Processing: Request restriction of data processing under certain circumstances.
Right to Data Portability: Request a copy of your data in a machine-readable format and transfer it to another data controller.
Right to Object: Object to data processing for specific reasons, such as direct marketing.
Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of the rights outlined above, please contact us using the contact information provided in this Policy. Upon receiving your request, we may need to verify your identity to ensure the security and confidentiality of your personal data.

Please note that while we strive to honor all legitimate requests, there may be certain limitations or legal grounds that prevent us from fully complying with your request. In such cases, we will provide you with a detailed explanation outlining the reasons for our inability to fulfill your request. These limitations are in place to protect the rights and freedoms of all individuals and to ensure that our data processing activities remain lawful and fair.

SECURITY MEASURES

We prioritize the protection of your personal data and employ various robust security measures to safeguard it against unauthorized access, alteration, disclosure, or destruction. Our security measures include, for example:

Access Controls: Restricting data access to authorized personnel only.
Encryption: Using advanced encryption for data in transit and at rest.
Secure Development: Incorporating security best practices in system and application design.
Employee Training: Providing ongoing data protection training to our employees.

We continuously update our security protocols to address evolving threats and technological advancements, ensuring the highest level of protection for your data.

Recommendations for Protecting Your Data

You play a crucial role in safeguarding your information. Here are some recommendations:

Use Strong Passwords: Create complex passwords and change them regularly.
Enable Two-Factor Authentication (2FA): Add an extra layer of security to your accounts.
Beware of Phishing: Verify sources before providing personal information.
Keep Software Updated: Regularly update your devices and software.
Avoid Sharing Credentials: Do not share your login credentials (such as usernames, passwords, or authentication codes) with anyone else.

Following these steps can significantly enhance the security of your personal data. For further assistance, please contact us.

AUTOMATED DECISION-MAKING AND PROFILING

We do not engage in automated decision-making processes that produce legal or similarly significant effects concerning data subjects. This means that any decisions impacting your rights or freedoms will always involve human intervention to ensure fairness and transparency. However, we may use profiling techniques to enhance and personalize your experience with our services. Profiling involves analyzing certain aspects of your personal data to predict your preferences and interests.

COMPLAINTS AND DISPUTE RESOLUTION

We take your concerns seriously and are committed to addressing any issues you may have regarding our data processing practices. If you have any questions or concerns, please do not hesitate to contact us. Our team will work diligently to address your concerns promptly and effectively.

In addition to reaching out to us directly, you have the right to lodge a complaint with the supervisory authority in Cyprus, which is the Office of the Commissioner for Personal Data Protection.

We are dedicated to ensuring that your concerns are resolved to your satisfaction and appreciate your trust in us.

POLICY MODIFICATIONS

We are committed to maintaining transparency and keeping you informed about how we handle your personal data. From time to time, we may make updates to this Privacy Policy to reflect changes in our practices, advancements in technology, or alterations in legal and regulatory requirements. Whenever we make changes to this Policy, we will publish the revised version on our website to ensure you always have access to the most current information regarding our data protection practices. For any significant changes that could affect your rights or the manner in which your personal data is processed, we will take additional steps to notify you directly.

CONTACT INFORMATION