Last updated on 23rd of May 2018
At ETET TRADING COMAPNY LTD (hereinafter “we”, “us” or “our”) the protection of your personal data is a top priority. Keeping your data secure and private is part of our philosophy for delivering high standards of services.
The new European Union (EU) Data Protection Law, the General Data Protection Regulation ("GDPR"), comes into effect on 25th of May 2018. The GDPR (EU) 2016/679gives individuals in the EU more control over how their data is used and places certain obligations on businesses that process the information of those individuals.
2. Who we are
3. Identity and contact details of the Data Controller and Data Protection Officer.
(a) Data Controller
ETET TRADING COMPANY LTD, a Cyprus private limited liability company, having registration number HE 289906, is the "Data Controller” pursuant to the GDPR, and related Cyprus Law, and determines how your personal data is kept and processed.
The main establishment and the central administration of the Data Controller is situated at Arch. Makariou III 40, Raptopoullos Building, 3021, Limassol, Cyprus.
(b) Data Protection Officer («DPO»)/ Responsible Person for GDPR
The DPO/ Responsible Person for GDPR may be contacted directly with regards to all matters concerning this policy and the processing of your personal data including the enforcement of all applicable and available rights.
Official requests may be made by post at Arch. Makariou III 40, Raptopoullos Building, 3021, Limassol, Cyprus, or electronically at email@example.com.
4. How do we collect personal data?
We collect and process different types of personal data which we receive from our clients in person or via our online website.
We do not collect any cookies.
6. What categories of personal data do we collect?
We collect and use several types of information the individuals we co-operate with, including information by which you may be personally identified and that is defined as personal data under applicable law such as your first and last name, address, contact details (telephone, email).
Should there be a need to further process the personal data for a purpose other than that for which they were initially collected, you will be informed in advance about the additional purpose and the relevant details in respect to the further processing.
With your explicit consent we may collect special categories of personal data. Pursuant to the definition given by the GDPR, these data may include racial or ethnic origin, political opinions, religious or philosophical beliefs, health data, trade union membership, the processing of genetic data, biometric data, data concerning health, sex life or sexual orientation and criminal records.
7. What lawful reasons do we have for collecting, processing and disclosing personal data
In order to proceed with a business relationship our clients must provide their personal data to us which are necessary for the required commencement, execution and continuation of a business relationship. This is a requirement under the relevant Anti-Money Laundering Law and the regulations of our Regulator (ICPAC- Institute of Certified Public Accountants Cyprus).
Failure to provide us with personal data prevents us from commencing or continuing a business relationship with the clients.
In accordance with GDPR we may rely on the following lawful reasons when we collect and process personal data to operate our business and provide our services:
• Compliance with legal obligation: We may process personal data in order to meet legal and regulatory obligations such as Anti-Money Laundering Law, Tax Law and the regulations of various supervisory authorities (e.g. the Institute of Certified Public Accountants Cyprus, IFAC and ACCA) that we are subject to for anti-money laundering purposes and due diligence purposes.
• Contract: We may process personal data for the purposes of providing our services in accordance with our terms and conditions and/ or any other contract that you have with us.
• Consent: We may rely on your freely given consent at the time you provided your personal data to us for a purpose of the process other than for the purposes set out hereinabove, then the lawfulness of such processing is based on that consent. You have the right to withdraw consent at any time. However, any processing of personal data will not be affected prior to the receipt of the withdrawal.
• Legitimate interests: We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. A legitimate interest is when we have a business or commercial reason to use our clients’ information. Instances of such processing activities can include, initiating legal claims, preparing our defense in litigation procedures, initiating complaints to our regulator etc.
8. Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
• Providing the requested services including professional advice and delivering reports related to our tax, advisory, audit and assurance, restructuring, mergers and acquisitions, consulting and other professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client;
• Customer management: to manage your account, to provide you with customer support and with notices about your account, including notices about changes to services we offer or provide through it;
• Administering, maintaining and ensuring the security of our information systems, applications and websites;
• Functionality and security: to detect, prevent, and respond to actual or potential fraud and illegal activities;
• Compliance: to enforce our terms and conditions and to comply with our legal obligations as these derive from the applicable laws or our regulators;
• Without the minimum personal data, our company will not be able to deliver the online received orders to customers. Courier companies require personal details in order to be in a position to contact the customer and complete the delivery as per customers request. Courier companies are liable by law to protect the personal details of our clientele. Courier companies domestic and non are complying to the GDPR rules and regulations.
9. Do we share personal data with third parties[SI3] ?
In the course of our business relationship our clients’ personal data may be provided to various departments within our Company.
Furthermore, the following third parties may also be the recipients of the personal data under the certain circumstances:
- Server providers
- Company accountants
- Courier companies
Third parties to whom we may disclose Personal Data may have their own privacy policies which describe how they use and protect Personal Data. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.
10. What about personal data security[SI4] ?
We have put in place appropriate technical and organizational measures including physical, electronic and procedural measures to protect personal data from loss, misuse, alteration or destruction. We restrict access to information at our offices so that only officers and/or employees who need to know the information have access to it. Those individuals who have access to the data are required to maintain the confidentiality of such information. In addition, we have trained our employees on how to handle, manage and process personal data, applied upgraded technical measures and transformed our policies and procedures in a way that will comply with the GDPR.
Please be aware that the transmission of data via the Internet is not completely secure. Users should also take care with how they handle and disclose their personal data and should avoid sending personal data through insecure email.
11. How long do we retain personal data?
We will keep our clients’ personal data for as long as we have a business relationship.
Once our business relationship has ended, we will hold your personal data on our systems for the longest of the following periods:
a) any retention period that is required by law or professional standards;
b) the end of the period in which litigation or investigations might arise in respect of the services or
c) as directed by our own internal retention policies or practices, the length of which may vary depending on the nature of the information that is held.
The personal data processed for the purposes of sending newsletters shall be kept with us until you notify us that you no longer wish your personal data to be used for this purpose.
13. What are your data protection rights?
Subject to the provisions of the GDPR, you have certain rights regarding the Personal Data we collect, process or disclose and that is related to you, including the right:
• To receive access to your personal data (right to access).
• To rectify inaccurate personal data concerning you (right to data rectification);
• to request deletion/ erasure of your personal data (right to erasure/deletion, “right to be forgotten”);
• to receive the Personal Data provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Data to another data controller (right to data portability);
• to object to the use of your personal data where such use is based on our legitimate interests or on public interests (right to object);
• in some cases, to request the restriction of processing of your personal data (right to restriction of processing);
• To withdraw the consent given to us with regard to the processing of your personal data at any time. Note that any withdrawal of consent will not affect the lawfulness of processing based on consent before it was withdrawn.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
14. How to raise a complaint
To exercise any of the above rights, or for any questions or complaints about our use of your personal data, please contact ourData Protection Officer/ Responsible Person for GDPR, either by post at Arch. Makariou III 40, Raptopoullos Building, 3021, Limassol, Cyprus, or electronically at firstname.lastname@example.org.
Complaints may also be lodged to the supervisory authority in Cyprus (Office of the Commissioner for Personal Data Protection, by post at 1 Iasonos Str. 1082, Nicosia, Cyprus. More information can be found at http://www.dataprotection.gov.cy.