Privacy Policy

Introduction

This Privacy Policy (‘Policy’) sets out the basis on which Panayiotis Z. Toulouras LLC (‘we’, ‘us’, ‘our’), with registration number HE 387435, being a Data Controller, may collect, use or otherwise process Personal Data in accordance with the General Data Protection Regulation (2016/679) and applicable Data Protection Laws of the Republic of Cyprus (‘the Law”). This Policy applies to all Personal Data in our possession or under our control.

We have used the following terms in this 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 Processor means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller;

Data Protection Officer means the person who is formally appointed with the purpose of ensuring that we are aware of and comp35ly with our 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:

1. from that data; or
2. from that data and other information to which we have or are likely to have access.

The Personal Data we may collect and use includes, without limitation, names and identification information such as email address, telephone numbers, copy of your passport, utility bill.

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;

For the purposes of this Privacy Policy, Personal Data includes Special Categories of Personal Data.

Why do we process your Personal Data

The purpose of the Processing of your Personal Data is largely based on each of the services that you have requested or that have been agreed with you.  In general, your Personal Data is processed, within the scope of our business relationship with you.

On what legal basis do we process your Personal Data

1. we may have a contractual arrangement with you and we need to process your Personal Data in order to fulfil our obligations (e.g. you are a client);
2. there may be a legal obligation for us to process your Personal Data (e.g. compliance with relevant anti-money laundering legislation);
3. we may want to fulfil a legitimate interest pursued by us or by a third party, in a manner that does not override your rights and freedoms;
4. you may have expressly asked us to do something or have otherwise given your clear consent to us to process your Personal Data (e.g. responding to a question you may have asked us).

Who we share your personal data with

Personal Data may be shared to the extent that this is necessary for the performance of the obligations in the course of or in connection with our provision of the services requested by you or any other business purposes related to or in connection with the accomplishment of the services assigned to us (e.g. to our agents located in various jurisdictions where we do business, financial institutions, public authorities) and in accordance with your specific instructions.

In addition, we may be required by applicable laws or by a court or upon governmental/public/supervisory/regulatory/competent authority requests to disclose certain Personal Data.

Transferring your Personal Data outside European Union (‘EU’)  and/or European Economic Area (‘EEA’)

We generally do not transfer Personal Data to countries outside of EU and/or EEA, (except where required by the purposes set out in this Policy). If we need to transfer your Personal Data outside of EU and/or EEA for any other purpose, we will obtain your consent for the transfer to be made and we will take all steps required to ensure that your Personal Data continues to receive our standards of protection.

How long will we store your Personal Data

We 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 us 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).

What are your rights in relation to your Personal Data

Right to access (commonly known as a "data subject access request"): You have the right to request a copy of the Personal Data we hold about you at any time;

Right to rectification: You have the right to ask us to correct any inaccurate Personal Data we hold about you;

Right to erasure: You have the right to ask us to delete your Personal Data from our records. Please note that we will not be able to delete your Personal Data when there is a legal obligation to keep that data (e.g. compliance with relevant anti-money laundering legislation or tax laws).

Right to restrict processing: You have the right to ask us to restrict the use of your Personal Data;

Right to object: You have the right to object to the collection and use of your Personal Data; (e.g. when we use your Personal Data on the basis of your consent you can withdraw that consent at anytime);

Right to data portability: You have the right to request the transfer of your Personal Data to another party;

Right to lodge a complaint: You have the right to lodge a complaint about the use of your Personal Data directly with the Office of the Commissioner for Personal Data Protection in Cyprus at.

Office address: Iasonos 1, 1082 Nicosia, Cyprus

Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus

Tel: +357 22818456

Fax: +357 22304565

Email: commissionerdataprotection.gov.cy

How can you exercise your rights in relation to your Personal Data

You can exercise all of your rights by contacting our Data Protection Officer on any of the contact details below:

Address: Griva Digeni 13, 5th Floor Office 501| 6030, Larnaca, Cyprus |

Email: Data Protection Officer at [email protected]

How do we protect your Personal Data

To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying or similar risks, we have introduced appropriate administrative, physical and technical measures.

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, we try to protect the security of the Personal Data by constantly reviewing and enhancing our information security measures.

Changes to this Policy

We may revise this Policy without any prior notice. Therefore, it is important to consult this page from time to time.

COOKIES POLICY

Our website uses cookie technology. Cookies are small files saved to your computer or mobile device that track, save and store information as well as your interactions and usage of our website. The primary purpose for collection of data from users to our site is to allow us to provide a smooth efficient and personalized experience while using our site. Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive, they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

We also collect other forms of non-personal information such as browsers used to access our website, search terms used to find the website, traffic referrals and links to our website. Cookies collected by us are used to enable certain functions and tools of our website, assist in the navigation of the website, track resources and data used on this site and remember computer settings. You may prevent your computer from accepting cookies by modifying the properties on your web browser (see your browser’s “Help” option on how to do this).

We also use the services of Google Analytics software to analyze traffic to our website. Neither of these programs creates individual profile for visitors, nor do we collect any personally identification information using these services. Data collected regarding site usage is compiled in aggregate to improve the performance of the website. If you do not wish your information to be included in this aggregated data through Google Analytics, modify the properties on your web browser to prevent your computer or mobile device from accepting cookies. Please read the Google privacy policy.

Types of Cookies

Strictly Necessary Cookies:

These cookies are necessary for the website in order to enable you to use certain features of the website, such as request specific services, setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Functionality Cookies:

These are used to allow the website to remember choices you make (such as language) and provide enhanced features to improve your web experience.

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.

Analytical Cookies:

These cookies are used to produce statistical analyses of the way users navigate the site (using computers or mobile devices), the number of pages viewed, or the number of clicks made on a page during navigation of a site.

Disabling Cookies

You can prevent the setting 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 other websites that you visit.--