Privacy Notice for ANTONIA CHR. SOFIANOU LLC
Introduction
At Antonia Chr. Sofianou L.L.C., we are committed to protect privacy of information and personal data entrusted to us.
The privacy statement set below, applies to personal data processed by Antonia Chr. Sofianou L.L.C. who is “the data controller” in accordance with the General Data Protection Regulation (GDPR).
It describes what personal data or information we gather about you, when and why we use that information for and to whom we give the information.
Read more about this privacy statement by referring to the content below:
To whom this privacy statement applies to and what it covers?
You can find how we will collect, handle, store and protect personal information about you when:
- providing services to you or to our clients,
- you use “our Website”, or,
- we perform any other activities that form part of the operation of our business.
We may refer to information that identify or may identify you or that may otherwise relate to you as “personal data” or “personal information”. We may also sometimes collectively refer to collecting, handling, using, protecting and storing your personal information as “processing” such personal information.
When we refer to “our Website” or “this Website” in this policy, we mean the specific webpages of www.sofianoulaw.com .
The Data Protection Principle
The Data Protection Act sets out principles governing the use of personal information which we must comply with, unless an exemption applies:
First Principle: Personal data shall be processed fairly and lawfully.
Second Principle: Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
Third Principle: Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
Fourth Principle: Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
Fifth Principle: Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Sixth Principle: Personal data shall be processed in accordance with the rights of data subjects under this Act.
What information do we collect and where do we collect it from?
In the course of providing services to you as a client we may collect or obtain personal data about you. This includes collecting personal data from you through arranged office meetings or site visits with and to you, telephone and electronic mail communication with you and through enquiries you place through our Website contact form.
The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you, for example as a result of legal requirements imposed on us.
Where we have no direct contractual relationship with you but obtain your personal data about you by our client, we take steps to ensure that the client has complied with the privacy laws and regulations relevant to that information.
How we use information about you?
We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(A) Where we need to perform the contract we have entered with you or in order to take certain steps prior to entering into a contract with you.
We will use your personal data to provide you with our services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you or other parties involved in the type of services we provide such as Antonia Chr. Sofianou L.L.C., associates and our service providers or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services.
(B) Where we need to comply with a legal obligation
We are required to comply with certain legal and regulatory obligations, as well as certain industry standards and field related professional ethics, which may involve the processing of personal data. We may, for example, need to carry out identity verifications through our “know-your-client” procedures, set-up anti-money laundering controls and comply with our tax reporting obligations. We may also need to provide information to a public body or law enforcement agency when we are so required.
(C) Where we have appropriate legitimate interests to use your personal data
In some cases, we may process your personal data to pursue business interests of our own or of third parties, provided your interests and fundamental rights do not override such interests. More specifically, we process your personal data:
- to maintain our accounts and records,
- to enhance the security of our network and information systems,
- to identify, prevent and investigate fraud and other unlawful activities,
- to manage our infrastructure, business operations and comply with internal policies and procedures,
- for financial accounting, invoicing and risk analysis purposes,
- to modify, personalize or otherwise improve our services,
- to defend, investigate or prosecute legal claims,
- for recruitment and business development purposes, and
- in order to receive professional advice from our advisors including our lawyers, accountants and consultants.
(D) Where you have given us your consent
We will only ask for your consent when we wish to provide marketing information to you in relation to our products and/or services that we think might be of interest to you. If you give us your consent, we may also contact you for market or research purposes from time to time.
You may withdraw your consent to such processing at any time by contacting [email protected] in any marketing communications, including emails that we send to you.
SENSITIVE DATA
To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either:
(i) you have given us your explicit consent to process that data;
(ii) the processing is necessary to carry out our obligations under employment, social security or social protection law
(iii) the processing is necessary for the establishment, exercise or defense of legal claims or
(iv) you have made the data manifestly public.
Use of personal information collected via our Website
In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:
- to tailor the content of our Website and to draw your attention to information about our products and services that may be of interest to you, for example news updates or presentations,
- to manage and respond to any request you submit through our Website.
Who we disclose your information to?
In connection with one or more of the purposes outlined in this privacy statement, we may disclose details about you to: third parties that provide services to us; competent authorities (including professional bodies and authorities regulating us or another party providing services to us and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in this privacy statement.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
- education and training to staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data on a ‘need to know’ basis; and
- technological security measures, including fire walls, encryption and anti-virus software.
How long we keep your information for?
We will hold your personal data on our systems for the longest of the following periods:
(i) as long as is necessary for the relevant activity or services,
(ii) any retention period that is required by law, or
(iii) the end of the period in which litigation or investigations might arise in respect of the services.
Your rights
You have various rights, under the Data Protection regulation, in relation to your personal data. In particular, you have a right to:
- Receive access to your personal data. You may request to obtain from ourselves a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data about you which we process. This provides you with the opportunity to have any incomplete or inaccurate data we hold and process about you, completed and/or corrected.
- Request erasure of your personal information. This right provides you with the opportunity request from us to erase personal data concerning you where there is no good reason for us to continue to process it.
- Object to processing of your personal data, including profiling, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please send an email to [email protected]
Right to complain
If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Office of the Commissioner for Personal Data Protection in Cyprus.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date at the end of the text. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.