(“we”, “us” or “our” in this privacy notice) respects your privacy. The protection of your personal data is of outmost importance to us. This privacy notice will inform you as to how we use and look after your personal data and tell you about your privacy rights and how the law protects you when:
- you visit our website www.queredecyprus.eu,
- you sign up to receive information about us, our services and events,
- you are a client or prospective client of us,
- you are a contact of us, and/or
- you are connected to a client or prospective client of ours or a matter in respect of which we receive instructions from a client of ours
We commit to operating in compliance with the Cypriot and European Legislation in the areas of Personal Data Processing, Privacy and Data Security. The legislation includes, inter alia, the General Data Protection Regulation (GDPR) and the ePrivacy Directive for the protection of private life in electronic communications. We also consider the Guidelines issued by the Office of the Commissioner for Personal Data Protection in Cyprus.
It is important that you read this privacy notice together with any other privacy notice we may provide on certain occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.
1. Important Information
is a Limited Liability Company in Cyprus under registration number 343656 with its registered office at 10 Patron, 6051 Larnaca, Cyprus.
Contact Person: Naira Madoian
Address: 57 Spyrou Kyprianou, M. Frangos Court, 5th
Floor, Office 502, 6051 Larnaca, Cyprus
Tel.: +357 24202551
Changes to the Privacy Notice
We may amend this Privacy Notice at any time. Any change will be valid from the publication of the updated Privacy Notice on our website
, and the publication date will be mentioned.
Your duty to inform us about changes in your personal details
It is important that the personal data we hold about you is accurate and current. Please keep us updated about your personal data changes during your relationship with us.
Links to Third-Party Websites
Our website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. What personal data do we collect about you?
Personal data is any information relating to an identified or identifiable person. We may collect, use, store and transfer different kinds of your personal data which we have grouped together as follows:
3. How do we collect your personal data?
- Identity Data, such as name, identity number, passport number, tax identification number, date of birth and gender.
- Contact Data, such as residential, correspondence and email addresses and telephone numbers.
- Financial Data, such as bank account details and other data necessary for processing payments and other details about payments to and from clients.
- Matter Data, such as communications and documents collated or created in respect of any matter.
- Communications Data, such as your preferences in relation to receiving information about us and our services.
- Special categories of personal data, such as nationality.
We use different methods and sources to collect your personal data including, inter alia, the following:
4. Why do we collect and process your personal data?
- Direct interactions with you. You may give us your data electronically, by phone, by post, during a meeting or otherwise. This includes personal data you provide when you:
- Contact us via our website;
- Provide us Identity, Contact, Financial and Matter Data when you become a client or prospective client of ours;
- Provide us with Identity or Contact Data when you become a contact of ours;
- We may also collect Identity, Contact, Financial and Matter Data about you if you are connected to a client of ours or if you are involved in a matter in respect of which we are instructed. Such data may be collected from our client, their or our agents or from a variety of other sources.
We use your personal data only for the following purposes:
- when it is necessary for the performance of a contract or in order to take steps prior to entering into a contract. This includes:
- to register you as a client;
- to provide our services as instructed by you or your organization;
- to be provided with services by you or your organization;
- to process payments, billing and collection.
- when processing is necessary for the purposes of the legitimate interests of our business, particularly:
- to administer and manage our relationship with you, including accounting, auditing, and taking other steps linked to the performance of our business relationship including identifying persons authorized to represent our clients, suppliers or service providers;
- to carry out background checks, where permitted;
- to analyze and improve our services and communications and to monitor compliance with our policies and standards;
- to manage access to our premises and for security purposes;
- to protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
- for insurance purposes;
- to exercise or defend our legal rights or to comply with court orders;
- to provide legal advice and legal services to our clients;
- to communicate with you to keep you up to date on the latest developments, announcements, and other information about our services and solutions (including briefings, newsletters and other information);
- to collect information about your preferences to personalize and improve the quality of our communications with you.
- when processing is necessary for compliance with a legal obligation, including maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions, etc.). This can include automated checks of personal data you provide about your identity against relevant databases and contacting you to confirm your identity or making records of our communications with you for compliance purposes.
We will not use your personal data for taking any automated decisions affecting or creating profiles.
on our website.
Change of purpose of processing
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
5. Who do we share your data with?
We may have to share your personal data in the following circumstances:
- with any member of our group of companies, including any of our subsidiaries and/or affiliate companies, for the purposes for providing our services as described herein.
- with third parties including advisers and expert witnesses, translators and other necessary entities and/or subcontractors, for the purposes for providing our services as described herein;
- to our client, if your personal data has been collected in the course of providing our services to our client;
- with service providers (including providers of IT services);
- with regulatory bodies, law enforcement agencies, or pursuant to an order of a court or a legal obligation, to enforce our terms of business or to protect the rights of our business, our employees and our clients and
- with any other third parties for example in the context of a merger, sale or restructuring of our business.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. How do we transfer your personal data outside European Economic Area (EEA)?
It might be necessary to transfer any personal data to countries outside the EEA for the purposes mentioned in this Privacy Notice and we will take steps to ensure that your personal data receives an adequate level of protection. In case where your personal data is transferred to a service provider for processing in any country outside the EEA that is not recognized by the EU Commission as providing an adequate level of protection for personal data, we will ensure that appropriate safeguards as per the EU Commission’s standard contractual clauses or by any other appropriate safeguard as foreseen under the applicable data protection law are provided.
7. What security measures do we take?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
- Site Access Control: unauthorized persons are not allowed to have access to areas where personal data are processed and in case that the provision of access to such persons is necessary, they do not remain unattended.
- System Access Control: only authorized persons have access to data processing systems.
- Data Access Control: authorized persons with access to data processing system have access only to the data they are authorized to access and are bound by confidentiality.
- Transfer Control: personal data are only transferred in prescribed manner and under certain circumstances.
- Disclosure Control: we always ascertain and check where and to whom data can be transferred by means of data transmission facilities.
- Order Control: personal data of a data subject is processed in strict accordance with the data subject’s instructions and the appropriate law.
- Availability Control: personal data is protected against accidental destruction or loss as all data is backed up.
- Breach Control: procedures to deal with any suspected personal data breach and for the notification of any applicable regulator or an affected data subject of a breach have been laid down.
Our security measures are audited regularly by external security experts in order to maintain our security level to international standards and to ensure that personal data is handled in a secure way.
8. How long do we keep your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for and in case where a client relationship existed we will retain your personal data for a period of at least five (5) years thereafter.
In general, to determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We may keep such data for longer periods for our legitimate business interests, or to comply with legal or regulatory obligations or to protect your or others’ vital interests.
In some circumstances you can ask us to delete your data: see below for further information.
9. What are your rights?
You have the following rights regarding your personal data:
Right of Access:
You have the right to access to your personal data. You can ask for a copy of the personal data we hold about you. There are situations where we may deny your request, for example, if making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information.
Right to Rectification
: It is our objective to keep your personal data accurate, current and complete. You have the right to request the correction of any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
Right to Erasure:
You have the right to ask us to delete or remove your personal data in case that
- there is no good reason for us continuing to process it
- you have successfully exercised your right to object to processing (see below)
- we may have processed your information unlawfully
- we are required to erase your personal data to comply with local law
You should note, though, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to Object
: You have the right to object to the processing of your personal data when 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. In some cases, we may demonstrate that we have compelling legitimate grounds which override your rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes.
Right to Restrict Processing:
This enables you to ask us to suspend the processing of your personal data in the following cases:
Right to Data Portability
- if you want us to establish the data’s accuracy
- when our use of the data is unlawful but you do not want us to erase it
- when you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
- if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
: You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Right to Withdraw Your Consent
: You have the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before the withdrawal of consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the abovementioned rights, please contact us at email@example.com
Right to file a complaint
You have the right to lodge a complaint with the Office of Cyprus Commissioner for Personal Data Protection. Please find more information at the official website of the Commissioner at www.dataprotection.gov.cy
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What do we need from you?
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to any other person. We may also contact you to ask for further information in relation to your request.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complicated or you have made more requests. In this case, we will notify you.
We recommend that you visit our website often in order to keep updated with the changes in our Privacy Notice. For previous versions of our Privacy Notice, please contact us at firstname.lastname@example.org