At C. Markou & Co LLC we care about the privacy and security of your personal information and we take measures to ensure that your personal information is properly handled while in our possession in the context of serving you in compliance with the Regulation (EU) 2016/679 of the European Parliament and of 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 (hereinafter the “General Data Protection Regulation” or the “Regulation”).
This Policy mainly explains when and why we collect personal information about visitors to our website and about natural persons in general we are offering services to, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
Name: Eleni Zafeiri
Tel.: +357 22377863
Fax: +357 22377860
Address: 2, Amfipoleos street, Marcou Tower, 2nd floor, Office 201, 2025 Strovolos, Nicosia.
Who are we?
C. Markou & Co LLC is a law firm based in Nicosia, Cyprus which is incorporated as a lawyers’ limited company in the Republic of Cyprus with registration number ΗΕ 274086 and authorised and regulated by the Cyprus Bar Association.
Address: 2, Amfipoleos Street, Marcou Tower, 2nd Floor, Office 201, 2025 Strovolos, Nicosia, Cyprus
Nature of business: Provision of legal and corporate services.
How do we collect information from you?
We obtain information about you when you use our website, particularly, when you contact us with a request, query or complaint through an online form or by email or other means of distance communication.
We also collect information about you through email or through our hard-copy forms sent by email or handed over in person, when you visit our offices or contact us requesting information about our services, when you request a quotation, when you submit an order or request the provision of a service or submit to us information about you and/or on behalf of your company(ies) during the course of providing a service to you and/or your company(ies) and when you pay us for services rendered or to be rendered.
What type of information is collected from you?
The personal information we collect is only information that we need in order to provide you with our services, to respond to your queries and to comply with our legal or regulator duties in relation to those services. Accordingly, the provision of such information is mandatory, in the sense that we will be unable to provide you with our services if we do not have the said information.
The personal information we collect may, depending on the nature of your case, include:
-date of birth,
-passport or identity card number,
-address and email address,
– health data, in case of dealing with road traffic or employment accidents or medical negligence
-copies of proof of address such as a utility bill, passport or identity card,
-bank reference letters,
-any contract or other document you furnish us in the context of requesting or receiving our services,
– source of funds and related information,
-your business relations such as other shareholders in your company or other service providers you have a co-operation with, when necessary or the beneficiaries, trustees or settlors of a trust, when applicable;
-all other information appearing on or requested through our KYC form.
We also collect any other information you provide to us by filling in and submitting web forms on our website or Facebook Page, such as a query, an order, rating, comment, request or complaint. If you have liked our Facebook Page, follow us on Facebook or connect with us through Facebook, we collect your Facebook name as well as any likes, views or comments you make on our Facebook posts, as well as anonymized statistics regarding how users engage with our page and Facebook profile.
We also collect any other information you provide by sending us emails, calling us or more generally, contacting us by any means of communication.
We may also collect information about you, not directly from you, but from third parties, mainly databases of information such as Lexis-Nexis and similar databases. This information consists of your professional activity, history, criminal records (if any), disputes you may have been involved or news, publications in which you may have appeared. Other such third parties may be your lawyers or bankers who are authorized to provide us with information of the type listed above on your behalf or other persons intended to be shareholders or beneficial owners of a company together with yourself or other corporate service providers who are authorized by you to disclose to us relevant information in order to enable us to serve you.
How is your information used?
We use your information lawfully in accordance with Article 6 (1)(a), i.e. for purposes you have consented to, Article 6 (1)(b), i.e. as necessary to conclude or perform a contract with you, Article 6(1)(c), i.e. to comply with obligations imposed by law (such as tax and anti-money laundering legislation), Article 6 (1)(f), i.e., as necessary for legitimate interests we pursue as a business and as far as sensitive data such as health data is concerned, in accordance with Article 9(2)(a), i.e. provided that you have given your explicit consent and Article 9 (2)(f), i.e. as necessary for the establishment, exercise or defence of legal claims. In relation to data relating to criminal records processing is based in accordance with Article 10, i.e. with your consent or to the extent permitted or required by national anti-money laundering legislation.
We provide more details immediately below to help you understand how exactly we use your information:
We may use your information in order to:
-respond to your orders/requests for services, requests or queries or communicate with you as explained below or send you communications which you have requested such as a reply to a query;
-process or examine orders/requests submitted by you;
-carry out all of our obligations relating to dealing with your case, arising from the contract between you and our company or take steps to enter into such contract;
-register and administer a company as per your request or provide you with requested expert advice or set up a trust as part of our services;
-to register you or your company with the tax authorities;
-arrange for the opening of bank accounts for you or your company as per your request;
-comply with or responding to reporting requirements or demands by regulatory authorities or as specified by the Cyprus law;
-confirm your identity and residence address;
-build up risk profiles with regards to the money-laundering risk associated with your registered or requested-to-be registered company;
-monitor transactions and activity for the purposes of preventing and reporting fraud or money laundering, assessing money-laundering risk and reduce credit risk;
-receive or request payment from you or your company;
Where and how long do we retain your information for?
Your information is mainly stored in physical files and computer servers in our premises in Cyprus.
By way of exception the personal information contained in the corporate email, is stored by Bravenet on its servers (England and Canada) and the information contained in Zygos Legal Practice Management software on the servers of Softline Computer Systems LTD seated in Cyprus.
We only keep information for as long as it is necessary for us to service you and as required to comply with legal or regulatory obligations to which we are subject, more specifically, those arising from fiduciary services, tax and anti-money laundering legislation as well as to be able to defend or institute any legal actions against or in the name of our company and to be able to keep a record of denied or terminated client relationship on the grounds of fraud, money-laundering or bad credit history. This data retention period is generally 10 years.
In case we have obtained your consent to collecting or using information for a particular purpose, such as marketing or commercial communications, we retain that information unless and until you decide to withdraw your consent or you object to its processing.
We retain information we collect about you in your capacity as a mere visitor to our website for one year.
Six months is generally the retention period applying to information we have collected as a result of yourself addressing a query or a comment to us through email or otherwise, when we have never had a contract with you.
In case of a maximum retention period specified by the Data Protection Commissioner applying to the domain of our services, we will immediately adhere to any such specified maximum retention period.
After the lapse of the aforementioned periods of retention, we remove it from our systems by deleting it or we fully anonymize it so that you can no longer be identified from it. In this latter case, we do not delete all of the information but only those pieces of information such as your name, address, email address that reveal that the said information belongs to you.
Who may have access to your information?
We will not sell or rent your information to third parties and we will not share it with third parties for marketing purposes.
We may pass your information to third party service providers as necessary to serve you, conduct our business or comply with legal or regulatory duties. Such third parties may be technical service providers providing us with the software systems or technical facilities (or their maintenance) necessary to conduct administrative tasks inherent in the provision of our services to you or the management of our company, and messengers or delivery companies we use to deliver or receive correspondence. We only disclose to them the personal information that is absolutely necessary to deliver the service or perform the said task and when required by the Regulation, we have a contract in place that requires them to keep your information secure and in accordance with the principles and rules of the General Data Protection Regulation and not to use it for any purposes other than to provide the service or complete the task as explained above.
We may also pass your information to our lawyers and accountants/auditors to the extent necessary to defend or institute legal claims and to comply with legal obligations with regards to financial accounts and tax reasons respectively.
We may also pass your information to associate lawyers and other service providers assigned to perform tasks on our behalf.
We may also transfer personal information to the banks in particular when you pay us by cheque or when and as part of providing banking assistance services to you. Banks within the EU are controllers of personal data themselves and are bound by all of the obligations of the General Data Protection Regulation and must have their own privacy policies which you should consult.
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets or sale of any ownership interest in our company to any third party or as part of any business restructuring or reorganization in which case we will take measures to ensure that all data protection principles and related rights as derived by the General Data Protection Regulation are fully complied with.
We may disclose your information to public, tax, regulatory, filing, supervisory or other authorities, if disclosure is required by law or an order issued by a court of law or as part of compliance with the rules and regulations governing the legal profession.
Finally, we may disclose your information to your lawyers, accountants, auditors or other professional advisers, banks or other financial institutions or payment service providers you are co-operating with, if requested by you or as necessary to provide you with requested services. Provided the aforesaid professionals and service providers are within the EU they are controllers of personal data themselves bound by all of the obligations of the General Data Protection Regulation and must have their own privacy policies which you should consult.
Other than the above, the recipients of personal data will be the authorized members of our staff which are contractually bound by confidentiality and security obligations and have been informed to handle your personal data in accordance with the rules and principles of the General Data Protection Regulation.
What are your rights?
You may at any time send us any of the following requests and we will meet them the earliest possible and, in any case, within 1 (one) month from the date of receipt of your request and inform you about the action we have taken. If your request is for any reason complex to examine or meet, we will ask you for an extension before the aforementioned one-month period expires.
If we have legitimate reasons to refuse to satisfy your request, we will inform you accordingly and in this case, you have the right to submit a relevant complaint to the Cyprus data protection authority, namely, the Data Protection Commissioner, http://www.dataprotection.gov.cy/ if you believe that our decision is unjustified.
These are the requests you can submit to us:
A request that we permanently delete all or some of your information from our records (right to be forgotten or to erasure), for example when we no longer have reasons to retain it.
A request for you to access your information that we keep in our records (right of access).
A request that we provide you with a copy of your information that exists in our records, in digital or hard copy form. If you require more than one copy, we may charge you a maximum of EUR100,00 as administrative costs (right to a copy).
A request that we update or correct your information that we keep in our records (right to rectification), for example, in case it is outdated or contains errors or inaccuracies.
A request that we provide you with information of yours we keep in our records in a structured, commonly used and machine-readable format or forward it in such form to another provider of your choice, if such forwarding or transfer is technically possible (right to portability). Please note that this right applies only in relation to data that you yourself has provided to us with and which we process by electronic means in the context of a contract between you and our company or because you have consented to us doing so.
A request that we stop doing anything with your information without however deleting it from our records (right to restriction of processing). In this case, we will restrict access to your data.
|A request that we stop processing your information on the basis of legitimate interests pursued by our company as explained under the fourth question of this Policy or in the name of the public interest (right to object). If we receive any such request, we will stop processing your data for the said purposes unless we have compelling reasons to refuse to do so and we will inform you accordingly.|
Please note that before acting upon any of your above requests, we may require you to prove your identity, if we are in doubt about your true or correct identity. If we cannot identify you, i.e., we do not hold personal data belonging to the person you are saying you are, we will inform you accordingly and we will not act upon your request.
What about the security of your information?
When you give us personal information, we take organizational and technical measures to ensure to keep it secure and protected against unauthorized disclosure, alteration, accidental loss or other violation.
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Transferring your information outside the European Union
We do not transfer your information to a country that is not a Member State of the EU unless, as explained above, when we use services from third parties such as Bravenet email.
In case it becomes strictly necessary to do so in order to provide our services, we will inform you beforehand. The data protection laws of such countries are not the same with those applying in the EU, however, when this is a country in relation to which there is not a European Commission decision on the sufficiency of its legal data protection regime as per Article 45 of the Regulation, we ensure that your personal data will be given analogous and/or appropriate respect and protection, specifically by signing with parties based outside the EU, relevant data sharing agreements using standard contractual clauses approved by the European Commission, in accordance with Article 46 of the Regulation.