Updated: Nov 2018

Privacy Policy

YIALLOURIDES & PARTNERS LTD (the “Firm”) are committed to protecting
and respecting your privacy.

This policy and any other documents referred to on it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will use it and treat it.
By providing us with your personal information and using our services, you are accepting and consenting to the practices described in this policy.

For the purposes of EU Regulation 2016/679 (the EU General Data Protection
Regulation) hereinafter referred to in this policy as the “GDPR”, the Data
Controller is YIALLOURIDES & PARTNERS LTD of 4 Sotiri Tofini Street,
AUDEH QUARTERS, 1 st Floor, Offices 102 & 103, 4102 Limassol, Cyprus.

INFORMATION WE COLLECT FROM YOU – We will collect and process the following data about you:

The information you give us. This is information about you that you give us by filling our client forms, engagement letters, retainers or by corresponding with us by phone, e-mail, in person or otherwise. It includes information you provide when you choose to use our services, participate in any firm event
and when you send any information to us under any capacity. The information you give us may include your name, address, e-mail address and phone number, financial information, personal description and photograph.

Information we receive from other sources. This information may be provided by our associates (introducers), the internet, newspapers, world check search engines etc. and will be used to complete your profile in our database.

We use information held about you in the following ways:

USES MADE OF THE INFORMATION

Information you give to us. We will use this information:

  • to carry out our obligations arising from any contracts entered into between
    you and us and to provide you with the information, products and services
    that you request from us;
  • to provide you with information about other services we offer that are similar
    to those that you have already used or enquired about;
  •  to notify you about changes to our service;

Information we receive from other sources. We will combine this
information with information you give to us and information we collect about
you. We will use this information and the combined information for the
purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR INFORMATION

You agree that we have the right to share your personal information with:

  • analytics and search engine providers that assist us in the improvement and
    optimization of our site;
  • credit reference agencies and/or banking/financial institutions for the purpose
    of assessing your credit score where this is a condition of us entering into a
    contract with you.
  • Compliance software for the purposes of complying with local and
    international regulations against money-laundering, fraud and the general
    prevention of crime and illegal activities and/or the cooperation with the
    authorities and/or the police

We will disclose your personal information to third parties:

  • In the event that this is necessary for the provision of services provided to you.
  • If YIALLOURIDES & PARTNERS LTD or substantially all of its assets are
    acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal and/or regulatory obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of YIALLOURIDES & PARTNERS LTD, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, anti-money laundering and credit risk reduction.

COLLECTION OF DATA UNDER MONEY-LAUNDERING POLICIES AND
PROCEDURES

The Firm conducts client due diligence enquiries on each new client and persons connected with them and conducts ongoing monitoring of existing clients. These enquiries are based on the FATF Recommendations and the EU Money Laundering Directives, although if additional information is required, that information will also be obtained. Where necessary for these purposes, we may seek relevant information from third-party data suppliers.
Where individuals have supplied personal data for this purpose we will only use it for that purpose and will keep it only as long as the relevant AML and data protection legislation requires.

Contact Information

If you have any questions in relation to this policy please contact us at: info@ayca.com.cy. You may send all Data Protection and Privacy related Inquiries to our address, marked “Confidential – For the attention of the YIALLOURIDES & PARTNERS LTD – Data Protection Officer”.

WHERE WE STORE YOUR PERSONAL DATA  

The data that we collect from you will be stored locally at our servers. However, certain email communications and/or data transmitted to us over email and/or other means of electronic transfer of documents may be transferred to, and stored at, a destination inside the European Economic Area (”EEA”). By submitting your personal data, you agree to this transfer and storing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and the GDPR.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

COOKIES

Our website does not use cookies.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing
purposes. We will usually inform you (before collecting your data) if we intend
to use your data for such purposes or if we intend to disclose your information
to any third party for such purposes. You can exercise your right to prevent
such processing by letting us know when we collect your data. You can also
exercise the right at any time by contacting us at: 4 Sotiri Tofini Street,
AUDEH QUARTERS, 1 st Floor, Offices 102 & 103, 4102 Limassol, Cyprus or
at info@ayca.com.cy

REVISIONS TO THIS POLICY

We may change this policy from time to time by updating this page. You
should check this page from time to time to ensure you are happy with any
changes.

ACCESS TO INFORMATION

You have the right to be provided and/or access and/or amend and/or rectify
information held about you. Under certain conditions, your right of access can
be exercised in accordance with the law. Any access request will be subject to a fee of €10 to meet our costs in providing you with details of the information
we hold about you, although we have the discretion to waive this.

We aim to comply with requests for access to personal information as quickly
as possible and will ensure that we comply with legislation unless exceptions
apply. In such cases, the reason for any delay will be explained in writing to
the data subject making the request.

In processing a request, the identity of the data subject has to be verified
before information will be released. No personal data will be disclosed to a
third party without the written consent of the data subject. We reserve the right
to refuse repeated/vexatious requests.