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DATA PROTECTION POLICY
‘Data Controller’ means the person or organization which determines when, why and how to process Personal Data and implements appropriate technical and organizational measures to comply with the Law;
‘Data Protection Officer’ means the person who is formally appointed with the purpose of ensuring that the Firm is aware of and complies with its data protection responsibilities and obligations according to the Law;
'Data Subject' means a living, identified or identifiable natural person about whom we hold Personal Data;
‘Personal data’ means data about the Data Subject who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Depending on the nature of your interaction with the Firm, some examples of Personal Data which the Firm may collect from you include, without limitation, names and identification information such as email address, telephone numbers, passports, marital status, utility bills;
Personal Data includes Special Categories of Personal Data.
‘Processing’ means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure or destruction;
‘Special Categories of Personal Data’ means the information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data;
‘the Law’ means Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data;
‘Third Party’ means the recipient of your Personal Data who may be bank institutions, governmental bodies, public authorities, embassies, any other organization, institution, courts and /or any other to whom your Personal Data will be provided for the scope of the services assigned to our Firm.
The Principals of Law
- Lawfulness, fairness and transparency: Be processed in a lawful, fair and transparent manner;
- Purpose Limitation: Be obtained only for specific, lawful purposes and not further processed in a way that is not compatible with those purposes;
- Data Minimization: Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which is processed (not excessive);
- Accuracy: Be accurate and kept up to date;
- Storage Limitation: Not be held for any longer than necessary;
- Confidentiality and Integrity: Personal Data should be processes in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures.
This Data Protection Policy (‘Policy’) sets out the basis which George Y. Yiangou LLC (‘Firm’), being a Data Controller, registered in the “Registry of Lawyers Companies” of the Cyprus Bar Association, with registration number 373, may collect, use, disclose or otherwise process Personal Data of Data Subject in accordance with the Law. This Policy applies to all Personal Data in Firm’s possession or under Firm’s control.
Collection, Storage, Use and Disclosure of Personal Data
The Firm may collect, storage, use and disclose your Personal Data for any or all of the following purposes:
- Are necessary for the performance of a contractual relationship between the Data Subject and the Firm;
- Performing obligations in the course of or in connection with our provision of the services requested by the Data Subject;
- Any other business purposes related to or in connection with the accomplishment of the services assigned to the Firm;
- Are necessary for compliance with a legal obligation to which the Firm is subject;
- Are necessary for the purposes of the legitimate interests pursued by the Firm or by a third party;
- Is required for complying with the Law and/or any applicable law, directive, regulation, guideline or to assist in law enforcement and investigations and/or upon governmental/public/ supervisory/regulatory/competent authority requests.
Protection of Personal Data
To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying or similar risks, the Firm has introduced appropriate administrative, physical and technical measures such as up to date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by the Firm, and disclosing Personal Data both internally and to Third Parties.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guarantee, the Firm tries to protect the security of the Data Subject’s Personal Data and is constantly reviewing and enhancing its information security measures.
Access to and Correction/Erasure of Personal Data
All Data Subject who are the subject of Personal Data held by the Firm are entitled to:
- Request for access to a copy of the Personal Data which the Firm holds about them or information about the ways in which the Firm uses or discloses their Personal Data or
- Request to correct or update any of their Personal Data which the Firm holds.
You can contact the Firm for this purpose in writing or via email to the Data Protection Officer at the contact details provided below.
The Data Protection Officer will respond to your access within thirty (30) days after receiving your access request.
Rights of Access, Data Portability, Correction and Erasure
- Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data the Firm holds about you and to check that the Firm is lawfully processing it;
- Request the transfer of your Personal Data to another party;
- Request correction of the Personal Data that the Firm holds about you. This enables you to have any incomplete or inaccurate information the Firm holds about you corrected;
- Request erasure of your Personal Data. This enables you to ask the Firm to delete or remove Personal Data where there is no good reason for us continuing to process it.
Accuracy of Personal Data
The Law requires our Firm to take reasonable steps to ensure Personal Data is kept accurate and up to date.
It is the responsibility of all who work with Personal Data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Staff should take every opportunity to ensure Personal Data is updated.
- Personal Data should be updated as inaccuracies are discovered.
- The Firm generally relies on Personal Data provided by you (or your authorized representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data in writing or via email to the Data Protection Officer at contact details provided below.
Retention of Personal Data
The Firm will retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
The Firm will cease to retain your Personal Data or remove the means by which the Personal Data can be associated with you, after seven years (7) where your relationship with the Firm has been terminated and/or as soon as it is reasonable to assume that such retention no longer serves the purposes for which the Personal Data were collected and are no longer necessary for legal or business purposes (except where retention is permitted or required by the Law and/or other applicable laws).
Transfer of Personal Data Outside of EU (European Union)
The Firm generally does not transfer your Personal Data to countries outside of EU (except where transfers of your Personal Data are required by the purposes set out in this Policy). If the Firm needs to transfer your Personal Data outside the EU for any other purpose, the Firm will obtain your consent for the transfer to be made and will take steps to ensure that your Personal Data continues to receive the Firm’s standards of protection.
List of Processors
- Newsletter Service: Zebra mail campaign
- Email Service: Zebra mail campaign
- Marketing Communications
Data Protection Officer
You may contact the Data Protection Officer if you wish to make any request, in the following manner:
A: 12 Kennedy Avenue, 2nd Floor | 1087, Nicosia, Cyprus | P.O. BOX: 24293, 1703, Nicosia, Cyprus
E: Data Protection Officer at email@example.com
Effect of Policy and Changes to Policy
This Policy applies in conjunction with any other policies and notices that apply in relation to the collection, use and disclosure of your Personal Data by the Firm.
The Firm may revise this Policy from time to time without any prior notice. Therefore, it is important to consult this page from time to time.
What are Cookies
You are advised that if you do not consent to the use and saving of cookies from this website on to your computer hard drive then you should take necessary steps within your web browser security settings to block all cookies from this website and its external serving vendors.
Other cookies may be stored on your computer hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. It should be noted that no personal information is stored, saved or collected.
Types of Cookies
The types of cookies used on this website can be classified into one of three categories:
Strictly Necessary Cookies: These are essential in order to enable you to use certain features of the website, such as submitting forms on the website.
Functionality Cookies: These are used to allow the website to remember choices you make (such as your language) and provide enhanced features to improve your web experience.
Analytical / Navigation Cookies: These cookies enable the site to function correctly and are used to gather information about how visitors use the site. This information is used to compile reports and help us to improve the site. Cookies gather information in anonymous form, including the number of visitors to the site, where visitors came from and the pages they viewed.
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser’s “Help” option on how to do this). Be aware that disabling cookies may affect the functionality of this and many other websites that you visit. Therefore, it is recommended that you do not disable cookies.
Security and Data Storage
We will treat all of your information in strict confidence and we will endeavor to take all reasonable steps to keep your personal information secure once it has been transferred to our systems. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, and data stored on the website and associated database.
Please note that the internet is not a secure medium and we cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the Internet and will not hold us liable for any data breach.
Learn more about Analytics cookies and privacy information
Use of IP Addresses. An IP address is a numeric code that identifies your computer on the Internet. We might use your IP address and browser type to help analyze usage patterns and diagnose problems on this website and to improve the service we offer to you. But without additional information your IP address does not identify you as an individual.
Hopefully the above information has clarified things for you. As it was previously mentioned, if you are not sure whether you want to allow the cookies or not, it is usually safer to leave cookies enabled in case it interacts with one of the features you use on our site. However, if you are still looking for more information, then feel free to contact us via email, at firstname.lastname@example.org