KYRIAKIDES, SAVVIDES & ASSOCIATES LIMITED Privacy Statement
KYRIAKIDES, SAVVIDES & ASSOCIATES LIMITED (referred to as ‘we’, ‘us’, ‘our’ or KSA) is committed to protecting your privacy and handling your data in an open and transparent manner. The personal data that we collect and process depends on the product or service requested and agreed in each case.
This privacy statement:
- provides an overview of how “KSA” collects and processes your personal data and tells you about your rights under the local data protection law and the EU General Data Protection Regulation (‘GDPR’),
- is directed to natural persons who are either current or potential customers of “KSA”, or are authorised representatives/agents or beneficial owners of legal entities or of natural persons which/who are current or potential customers of “KSA”.
- is directed to natural persons who had such a business relationship with the Bank in the past,
- contains information about when we share your personal data with other third parties (for example, our service providers or our associates).
In this privacy statement, your data is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data or any such action as “processing” such personal data.
For the purposes of this statement, personal data shall mean any information relating to you which identifies or may identify you and which includes, for example, your name, address, identification number.
- Who we are
“KSA” is a licensed Audit, Accounting and Administrative Service Provider registered in Cyprus under registration number 146879 as limited liability company having its registered office and head offices at 5, Spatharikou Street, 4004 Mesa Geitonia, Limassol
If you have any questions, or want more details about how we use your personal information, you can contact our Data Protection Officer at the above address or email: Panayiotis.firstname.lastname@example.org
- What personal data we process and where we collect it from
We collect and process different types of personal data which we receive from our customers (potential and current) in person or via their representative or via our alternative channels of communication such as our website, in the context of our business relationship.
We may also collect and process personal data which we lawfully obtain not only from you but from other third parties e.g. Banks, Public Authorities, companies referring you to us, your clients, your suppliers etc.
We may also collect and process personal data from publicly available sources (e.g. the Department of Registrar of Companies and Official Receiver, the Land Registry, the Bankruptcy Archive, commercial registers, the press, media and the Internet) which we lawfully obtain and we are permitted to process.
If you are a prospective customer or an authorised representative/agent or beneficial owner of a legal entity or of a natural person which/who is a prospective customer, the relevant personal data which we collect may include:
Name, address, contact details (telephone, email), identification data, birth date, place of birth (city and country), marital status, employed/self-employed, if you hold/held a prominent public function (for PEPs), FATCA / CRS info, authentication data [e.g. signature].
When we agree to provide services to you or the legal entity you represent or beneficially own, then additional personal data will be collected and processed which may include:Current income and expenses, employment history, property ownership and personal debts, number of dependent children, personal investments and investment income, life insurances (life insurance companies, policy numbers, current surrender values, other banking relationship details, tax residence and tax ID, credit reference agency data [e.g. OFAC, Worldcheck], residence or work permit in case of non-EU nationals employment position [e.g. as per corporate certificates of directors/shareholders].
- Children’s data
We understand the importance of protecting children’s privacy. We may collect personal data in relation to children only provided that we have first obtained their parents’ or legal guardian’s consent or unless otherwise permitted under law.
- Whether you have an obligation to provide us with your personal data
In order that we may be in a position to proceed with a business relationship with you, you must provide your personal data to us which are necessary for the required commencement and execution of a business relationship and the performance of our contractual obligations. We are furthermore obligated to collect such personal data given the provisions of the money laundering law which require that we verify your identity before we enter into a contract or a business relationship with you or the legal entity for which you are the authorized representative / agent or beneficial owner. You must, therefore, provide us at least with your identity card/passport, your full name, place of birth (city and country), and your residential address so that we may comply with our statutory obligation as mentioned above.
Kindly note that if you do not provide us with the required data, then we will not be allowed to commence or continue our business relationship either to you as an individual or as the authorized representative/agent or beneficial owner of a legal entity.
- Why we process your personal data and on what legal basis
As mentioned earlier we are committed to protecting your privacy and handling your data in an open and transparent manner and as such we process your personal data in accordance with the GDPR and the local data protection law for one or more of the following reasons:
- For the performance of a contract
We process personal data in order to perform based on contracts with our customer but also to be able to complete our acceptance procedure so as to enter into a contract with prospective customers.
The purpose of processing personal data depends on the requirements for each service and the contract terms and conditions provide more details of the relevant purposes.
- For compliance with a legal obligation
There are a number of legal obligations emanating from the relevant laws to which we are subject as well as statutory requirements, e.g. the Money Laundering Law, Tax laws. There are also various supervisory authorities whose laws and regulations we are subject to e.g. the Cyprus Institute of Certified Accountants. Such obligations and requirements impose on us necessary personal data processing activities for identity verification, compliance with court orders, tax law or other reporting obligations and anti-money laundering controls.
- For the purposes of safeguarding legitimate interests
We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. Examples of such processing activities include:
- Initiating legal claims and preparing our defence in litigation procedures,
- Means and processes we undertake to provide for the KSA’s IT and system security, preventing potential crime, asset security, admittance controls and anti-trespassing measures,
- Setting up CCTV systems, e.g. at the entrance of our offices and at the entrance of each floor, for the prevention of crime or fraud,
- Measures to manage business and for further developing products and services.
- Sharing your personal data within “KSA” for the purpose of updating/verifying your personal data in accordance with the relevant anti-money laundering compliance framework,
- You have provided your consent
Provided that you have given us your specific consent for processing (other than for the reasons set out hereinabove) then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.
6. Who receives your personal data
In the course of the performance of our contractual and statutory obligations your personal data may be provided to various departments within “KSA”.
It must be noted that we may disclose data about you for any of the reasons set out hereinabove, or if we are legally required to do so, or if we are authorized under our contractual and statutory obligations or if you have given your consent.
Under the circumstances referred to above, recipients of personal data may be, for example
- Supervisory and other regulatory and public authorities, inasmuch as a statutory obligation exists. Some examples are the income tax authorities, OUR MONITORING AUTHORITY, THE Registrar of Companies etc.
- Credit and financial institutions.
- Share and stock investment and management companies,
- Your suppliers or customers.,
- For our anti-money laundering process, such as credit reference agencies,
- External legal consultants,
- Financial and business advisors,
- Auditors and accountants,
- Transfer of your personal data to a third country or to an international organisation
Your personal data may be transferred to third countries [i.e. countries outside of the European Economic Area] in such cases as e.g reporting obligation under Tax law or you have given us your consent to do so. Processors in third countries are obligated to comply with the European data protection standards and to provide appropriate safeguards in relation to the transfer of your data in accordance with GDPR Article 46.
- To what extent there is automated decision-making and whether profiling takes place
In establishing and carrying out a business relationship, we generally do not use any automated decision-making. We do not process your data automatically, with the goal of assessing certain personal aspects (profiling) for marketing purposes.
- How we treat your personal data for marketing activities and whether profiling is used for such activities
We may process your personal data to tell you about services and offers that may be of interest to you or your business.
The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services. We study all such information to form a view on what we think you may need or what may interest you. We do not evaluate your personal aspects automatically for marketing purposes.
We can only use your personal data to promote our services to you if we have your explicit consent to do so or, in certain cases, if we consider that it is in our legitimate interest to do so.
You have the right to object at any time to the suspicion of processing of your personal data for marketing purposes, which includes the suspicion of profiling, by contacting at any time our Data Protection Officer.
- How long we keep your personal information for
We will keep your personal data for as long as we have a business relationship with you [as an individual or in respect of our dealings with a legal entity you are authorized to represent or are beneficial owner].
Once our business relationship with you has ended, we may keep your data for up to ten (10) years in accordance with the directive of the Data Protection Commissioner (http://www.dataprotection.gov.cy).
We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.
For prospective customer personal data [or authorized representatives/agents or beneficial owners of a legal entity prospective customer] we shall keep your personal data for 6 months from the date of notification of the rejection of your application as per Data Protection Commissioner directive (http://www.dataprotection.gov.cy).
- Your data protection rights
You have the following rights in terms of your personal data we hold about you:
- Receive access to your personal data.This enables you to e.g. receive a copy of the personal data we hold about you and to check that we are lawfully processing it. In order to receive such a copy you can address your enquiry to our office.
- Request correction [rectification]of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal information.This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no good reason for us continuing to process it.
- Object to processing of your personal datawhere we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
You also have the right to object where you suspect that we are processing your personal data, for direct marketing purposes. This also includes suspicions of profiling inasmuch as it is related to direct marketing.
If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
- Request the restriction of processingof your personal data. This enables you to ask us to restrict the processing of your personal data, i.e. use it only for certain things, if:
- it is not accurate,
- it has been used unlawfully but you do not wish for us to delete it,
- it is not relevant any more, but you want us to keep it for use in possible legal claims,
- you have already asked us to stop using your personal data but you are waiting us to confirm if we have legitimate grounds to use your data.
- Request to receive a copyof the personal data concerning you in a format that is structured and commonly used and transmit such data to other organisations. You also have the right to have your personal data transmitted directly by ourselves to other organisations you will name [known as the right to data portability].
- Withdraw the consent that you gave uswith regard to the processing of your personal data at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us.
You can also contact our Data Protection Officer.
We endeavor to address all of your requests promptly.
Right to lodge a complaint
If you have exercised any or all of your data protection rights and still feel that your concerns about how we use your personal data have not been adequately addressed by us, you have the right to complain in writing. You also have the right to complain to the Office of the Commissioner for Personal Data Protection. Find out on their website how to submit a complaint (http://www.dataprotection.gov.cy).
- Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
We will notify you appropriately when we make changes to this privacy statement and we will amend the revision date at the top of this page. We do however encourage you to review this statement periodically so as to be always informed about how we are processing and protecting your personal information.
- Frequently asked questions
To help you understand the basic principles of data privacy law and address some of the common questions that arise with regard to the protection of your personal data, please contact the Data Protection Officer of “KSA”
The General Data Protection Regulation (EU) 2016/679 shall apply from 25 May 2018. Until then, the Processing of Personal Data (Protection of Individuals) Laws 2001 till 2012 remain in force.