Your Privacy is important to us
The purpose of this Privacy Policy (“Policy”) is to provide a clear explanation of when, why and how Elias Christofi & Co. Ltd collects, handles, uses and discloses your personal data.
Elias Christofi & Co. Ltd abides strictly by the European Union (EU) Data Protection Law, the General Data Protection Regulation (“GDPR”), which came 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.
Who we are
Elias Christofi & Co. Ltd is a company registered in Cyprus under registration number HE 300107 with its registered office located at 14 Spyrou Kyprianou Avenue, Office 101, 3070, Limassol, Cyprus, licensed by the Institute of Certified Public Accountants of Cyprus (ICPAC).
Elias Christofi & Co. Ltd is a Cyprus private Ltd liability company, having registration number HE 300107, is the “Data Controller” pursuant to the GDPR, and related Cyprus Law, and determines how your personal data is kept and processed.
We have designated a Data Protection Officer (“DPO”), who is responsible to monitor compliance with this privacy policy as well as the applicable Laws and liaise with the Cyprus Supervisory Authority, namely the Office of the Commissioner for Personal Data Protection. 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.
The main establishment and the central administration of the Data Controller and the Data Protection Officer is situated at 14 Spyrou Kyprianou, 3070, Limassol, Cyprus.
Who this Privacy Policy is directed to
This privacy policy is directed to natural persons/legal entities (hereinafter our “clients”) who are either past, current or potential clients, or are authorized representatives/agents of past, current or potential clients, or are beneficial owners in legal entities who are past, current or potential clients. It is also directed to all clients who visit our public web-site at www.eliaschristofi.com and/or our social media platforms, describing how we collect, handle, use, and disclose your personal information obtained through our public web-site/social media platforms.
Information collection & Use and disclosure
When you contact us (via any portal) or when you visit our public website, Elias Christofi & Co. Ltd may need from you to provide personally identifiable information, such as your name, company, e-mail address and phone number (“Personal Information”). We may receive personal information from our clients in person or via their representatives in the context of our business relationship or via our email or public website or social media.
We may obtain the following categories of personal data about individuals in order to conduct our business activities:
- Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).
- Professional details (e.g., job and career history, educational background and professional memberships).
- Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).
- Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details).
The purpose for requesting the particular information may involve, corresponding with and/or contacting you and/or fulfilling your requests for certain services and information. To deliver relevant website content and advertisements to you (via email, telephone, social media platforms) and measure or understand the effectiveness of the advertising we serve to you, as part of our marketing strategy. To make suggestions and recommendations to you about goods or services that may be of interest to you. To use data analytics to improve our website, products, services, marketing, customer relationships and experiences. This is necessary for our legitimate interests (to study how visitors (including our public web-site visitors) or customers use our products and/or services, to develop them, to grow our business and to inform our marketing strategy).
In order to provide the requested services or in other cases in the course of our business relationship, your personal data or our clients’ personal data may be provided to various departments within our Company and we may need to transfer your Personal Information among our members of staff of Elias Christofi & Co. Ltd or to members of staff of our group of companies or to our associates where absolutely necessary. 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 note that if you reply to Elias Christofi & Co. Ltd address in one of our informative e-mails or otherwise correspond with us via any other portal (including but not limited via our public web-site or social media), your communication will not create a service provider-client relationship with us.
By consenting to supply Elias Christofi & Co. Ltd with personally identifiable data, such as your name, address, email address and telephone number, Elias Christofi & Co. Ltd will not, in any way, directly or indirectly, sell or transfer any of this information to any unauthorised (by the law) third party. Any information supplied will be confidential and will be handled in accordance with the applicable laws and regulations. We may in limited circumstances bear a legal obligation to share Personal Information with government authorities, supervisory and other regulatory and public authorities, whereby a statutory obligation exists (such as the Institute of Certified Public Accountants Cyprus, the Registrar of Companies, criminal prosecution authorities) or others, as required to protect the interests of Elias Christofi & Co. Ltd and/or other companies within our group or as required by a court order.
Access, Correction, Complaints and Cancellation
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:
- to receive access to your personal data (right to access).
- to rectify inaccurate personal data concerning you (right to data rectification);
- to request deletion/ erasure of your personal data (right to erasure/deletion, “right to be forgotten”);
- to receive the Personal Data provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Data to another data controller (right to data portability);
- to object to the use of your personal data where such use is based on our legitimate interests or on public interests (right to object);
- in some cases to request the restriction of processing of your personal data (right to restriction of processing);
- to withdraw the consent given to us with regard to the processing of your personal data at any time. Note that any withdrawal of consent will not affect the lawfulness of processing based on consent before it was withdrawn.
In such case, 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.
For service provision to any client, we will retain relevant personal information for as long it is required to do so according to our regulatory obligations or professional indemnity obligations and in compliance with our obligations under the EU General Data Protection Regulation or similar legislation around the world. We may then destroy or proceed with pseudonymization such files without further notice or liability.
If you feel that your personal data has been processed in a way that does not meet the General Data Protection Regulation (GDPR), you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then notify in regards the progress and outcome of your complaint. The supervisory authority in Cyprus is the Information Commissioner’s Office.
Revisions to this privacy statement
Elias Christofi & Co. Ltd reserves the right to change this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.
Cookies
We may 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.
Our website in some cases uses cookies to collect personally identifiable information (such as mobile number, email address, etc.), these cookies might be stored and kept safe for communication and operational purposes.
To find out more about cookies, you can visit http://www.allaboutcookies.org.
Who to contact if you have any question or raise a complaint
Please contact us if you have any questions about our privacy policy or information we hold about you or if you need to raise a complaint:
Christina Marie Christofi
Tel: +357 25 338 372
Fax: +357 25 338 515
14, Spyrou Kyprianou, Office 101
3070, Limassol, Cyprus
Email: legal@eliaschristofi.com