The Firm reserves the right to update this Policy from time to time. In the event that the Firm materially changes this Policy including how we collect, process or uses clients’ personal information, the revised Policy will be uploaded on our website, so please review it frequently. Any personal information we hold will be governed by our most current Policy. If we make changes we consider to be important, we will communicate them to you.
Please note that this Policy is addressed to current clients and potential clients. By accessing our website including using any of the communication channels to contact us, we consider that you have read and understood the terms of this policy and how we process any information you disclose to us including personal data prior to becoming a client.
Information that we collect and store
The Firm collects the necessary information required to provide clients with the services required and to meet our legal, contractual and statutory obligations.
As part of our business we collect personal data from clients and potential clients that include the following:
- name, surname and contact details (including postal addresses and email addresses)
- date of birth and gender
- Information required to meet our legal and regulatory requirements, in particular in respect of anti-money laundering legislation, including information on source of funds and source of wealth, including details about your assets and liabilities, account balances, trading statements, tax and financial statements
- Information provided in the course of the provision of our services (for example, information on professional relationships and background, transactions entered into, tax status, disputes and court proceedings engaged in)
- Banking and financial information, such as payment related information
- Meetings attended and visits to our offices
- Any other information you may provide to us.
Identification documentation, as required under anti-money laundering legislation or other legislation relevant to the services we provide to you, includes:
- driver’s licence
- national identity card (if applicable)
- utility bills
- trust deed (if applicable)
- other information we consider necessary to our functions and activities.
If you are a corporate client we are required to collect additional information such as corporate documents of address, shareholders, directors, officers including additional personal information on the shareholders and directors. We have the right to ask any additional information we deem necessary to be compliant with our legal and regulatory requirements.
We may record any communications, such as electronic that we have with you in relation to the services we provide to you and our relationship with you.
How We Use Your Personal Data
The Firm uses clients’ personal information only as required to provide quality service and security to its clients. We only retain your data for as long as is necessary and for the purposes specified in this statement. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:
- Company formation and administration services
- Fiduciary services
- Bank account opening
- Support on creating and maintaining business substance
Provision of Asset Protection
- Succession Planning and Trustee Services
- Tax Non-Domicile Registration and reporting
Real estate, Citizenship and Migration Services
- Relocation, Citizenship and Migration Services
- Wills, probate and re-sealing and estate administration
- Estate planning and taxation
- Employment permits
Provision of Investment Services
- Fund Establishment, Licensing and Management Services
- Representation of clients for Court cases and tribunals
- Banking litigation
- Restructuring and reorganisation services
- Insolvency processes and liquidation services
- Debt restructuring
How Long We Keep Your Data
Our Firm only keeps data for as long as necessary to fulfil the purposes (as set out above) for which we collected it. Please be advised that we keep your data for 5 years from the conclusion of our relationship with you. This is subject to certain exceptions such as for trusts (where, in each case, records may be kept indefinitely) or in instances where the personal data is relevant to a dispute after termination of the relationship or where the data cannot be deleted for legal, regulatory or technical reasons.
At any time, you are entitled to contact us and request:
- Right to access, request copy, correct or delete any personal information that the we collected, and which was subject to processing but also the ways how data was obtained, the reason for processing, what data categories were processed and the basis of the automated processing system.
- Right to restrict processing. You have the right to request the restriction or suppression of your personal data. The Company to comply with Laws and Regulations may store the personal data but will not use it.
- Right to object. You have the right to object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms.
- Right to withdraw consent. Where we have obtained your consent to process your personal data you may withdraw this consent at any time.
- Right of erasure. You have the right to request erasure of your personal data. It shall be noted that the Firm may refuse to satisfy your request as under any other legal obligations that the Company is subject to, we may be required to keep the information that you provide to us.
In case you disagree with the way we handle your personal data and/or you want to exercise any of your rights above, please contact us by sending an e-mail to email@example.com and we shall reply to you within 30 days. In the case you have unresolved concerns you have the right to complain to the relevant data protection authority.
Who may we disclose personal information to
As part of using your personal information for the purposes set out above, we may disclose your information to:
- affiliates who provide fiduciary services and other related corporate services;
- auditors, accountants, tax advisors or other advisers auditing, assisting with or advising on any of our business purposes;
- courts, tribunals and applicable regulatory authorities as agreed or authorised by law or our agreement with you
- government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests;
- any registrar of a public register where the data is to be included in a public registry;
- anyone authorised by you.
We endeavor to disclose to these third parties only the minimum personal data that is required to perform their contractual obligations to us. Our third-party service providers are not permitted to share or use personal data we make available to them for any other purpose than to provide services to us.
In the event that any such third party is outside of the European Union and where the data being transferred would include personal data which would be protected under applicable Data Protection regulation we will ensure we meet the relevant requirements of that Data Protection regulation prior to carrying out any such transfer.
When and how do we obtain your consent
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this statement or where there is a legal requirement, such as:
- to perform our contractual obligations towards you
- to be compliant with the legal and regulatory requirements
- to pursue our legitimate interests
Where our use of your personal information does not fall under one of above mentioned grounds we require your consent. Such consent shall be freely given by you and you have the right to withdraw your consent at any time by contacting us using the contact details set out in this privacy notice or by unsubscribing from email lists.
Data Protection Officer, L.Loucaides – Theophanous LLC, 3 Marathonos, Mali house, 8011, Paphos, Cyprus