At C. Efstathiou Audit 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) 2016/679 gives 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
C. Efstathiou Audit Ltd is a company registered in Cyprus under registration number HE 53015 with its registered office located at 8 Kennedy Avenue, Office 201, 1087, Nicosia, Cyprus licensed by the Institute of Certified Public Accountants of Cyprus (ICPAC) to provide and Auditing Services (Certificate number E186/A/2013). C. Efstathiou Audit Ltd is also providing business consulting Services.
4. Identity and contact details of the Data Controller and Data Protection Officer.
(a) Data Controller
C. Efstathiou Audit Ltd, a Cyprus private Ltd liability company, having registration number HE 53015, 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 8 Kennedy Avenue, Office 201, 1087, Nicosia, Cyprus.
(b) Data Protection Officer («DPO»)
The DPO 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 8 Kennedy Avenue, Office 201, 1087, Nicosia, Cyprus, or electronically at email@example.com.
5. 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 their representatives in the context of our business relationship.
We may also collect and process personal data which we lawfully obtain not only from our clients and their representatives but also from other third parties e.g. other service providers, professionals such as accountants and lawyers or online screening tools.
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 are permitted to process.
We also collect and process certain browsing data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. We collect first party Cookies that is set by the domain, such as the computer you are using to access the internet, or the specific website that you have visited. We use the two main types of cookies, persistent and session cookies. A persistent cookie remains on your device after you have visited our website. These cookies will help us identify you as a unique anonymous visitor to our website by storing a randomly generated number. A session cookie is temporary and only exists for the period you access the website for (or until the browser is closed after visiting our website). This particular type of cookie assists us by helping our website remember your selections and choices whilst visiting our website and therefore avoids you having to re-enter information. This type of cookie is anonymous and does not contain personal information and cannot be used to identify you.
7. 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), identification data (such as passport, driver’s license or ID), birth date, place of birth (city and country), employment status (employed/self-employed), curriculum vitae, taxation and other related financial details, reference letters, whether you hold/held a prominent public function (for PEPs), FATCA / CRS info, authentication data (e.g. signature).
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.
8. 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:
9. 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:
10. Do we share personal data with third parties?
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:
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.
11. What about personal data security?
We have put in place appropriate technical and organisational 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.
12. 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:
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.
14. 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:
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.
15. 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 our Data Protection Officer, either by post at 6 Neoptolemou street, 1087, Nicosia, 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, Republic of Cyprus. More information can be found at http://www.dataprotection.gov.cy.