Any reference to the following ;(‘’we’’, ’’us’’, ‘’our office’’) means Stavros Ioannou LLC and its affiliated fiduciary services provider companyIoan net Secretarial Services Ltd.
Apart from regulations that govern our profession, confidentiality has been our office top priority. We’ve been always taking the necessary preventive measures to safeguard all the details and information that we collect from our clients.
We strictly safeguard the confidentiality and privacy of information that is collected. Please read carefully the privacy statement to find out more about the collection, use, process, share and protection of the Personal Information that is obtained.
We do not collect any information from visitors of our website, since the information filling fields in not available.
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It is our Office’s policy not to collect or process information about anyone under the age of 13 (thirteen) unless we obtain parental or guardian consent for any data processing activity.
We collect information once it is provided by you or your representatives either by email, post or otherwise, or upon our request based on your instructions for the provision of various services.
Process of Personal Data
We use the information that is necessary for the fulfilment of your request. In case that additional is necessary, you will be notified prior to the provision of the same.
The General Data Protection Regulation entitles the use and/or processing of personal information, where deems applicable under the law to do so. Although, we are required to inform you the lawful basisof the same. Consequently, the use of your personal information shall extent in the essence of the following conditions:
- Provision of Services by the Firm, Affiliate or Associated Companies
- Performance of Agreement
- Legal Obligation
- Execution of Payments
- Bank Account Opening Procedures
We may also require the provision/collection of accurate and updated Personal Information in terms of KYC and Due Diligence policies; verification purposes as outlined in the framework of complying with the the Law (Ν. 188(I)/2007),‘’Prevention and Suppression Money Laundering’’), the Law on Provision Administrative Services 196/(I)2012 or to any other related legislation and directive passed by the Cyprus Bar Association that falls under the ‘’Compliance Framework’’. The personal information and/or corporate documentation, which must necessary required, always depends on the instructions of the client and may unrestrictedly include: name-surname, educational background, race, residential address, utility bills, email, fax, skype,tax identification number, source of wealth/income, business activities, passport, identity card, marital status, children or relatives’ identifications, past private and public conditions.
We are obliged within the Compliance Framework to use the Personal Information that we possess for verification purposes; by performing searches on public or private databases.
Omission to provide Personal Information
It is our office policy prior to the provision of certain services, to seek from your personal information. If you fail to provide the requested information we may not be able to offer you the requested services.
The Personal Information collected may be kept electronically in personal computers or hard copies (papers).
Cases when your private information is shared
Upon your instructions and the needs of carrying out the same, it is possible your information to be shared with our associates, which are directly/ indirectly related for the provision of requested services. Such Associates shall be the Auditors, Legal Consultants, Tax Auditors, with whom you have signed an Engagement Letter. Moreover, if you wish our office to apply for the opening of a bank account or act on your behalf as Bank introducers, the bank is also recipient of your personal information. Also, it might be necessary based on your instructions, to contact and share your personal information with a third party if is required for the performance of such service; registration (i.e. Land Registry, Registrar of Companies).
Your personal information is provided to our service providers/associates only if we are satisfied that they are also taking the relevant measures for the protection of your personal information.
Disclosure of Personal Information
The disclosure and exchange of your personal information can arise only upon a Court order or within the law enforcement agencies and/or regulatory bodies to comply with our legal regulatory obligations that fall under the Compliance Framework.
Location of Personal Information
Your information is kept confidentially in our office and/or into our associates premises and/or service providers, who linked to the provision of the services upon your instructions.
Retention Period of the personal information
Your personal data and records is retained during the provision of services and for a furtherperiod of 5 years (or longer if applicable) after the dateof terminating services. After the expiration of 5 years, all documentation that is related to you will be destroyed, unless you sent us a Written Notification that you wish to be returned to you.
Right to access personal information
Personal data shall be accessible by our Office’s employees.
You have the right by sending first a Written Notification to our Office, to access, correct, rectify and/or delete your personal information that we retain for you (‘’data subject access request’’) and/or ask for a copy of the same and/or request the legality of retention, free of any charges.
You have the right to give instructions for the handling of your data after your death.Also, you can transmit your personal data to another Controller without hindrance from our Office.
Lastly you have the right of complaint with the competent data protection authority.
For any query/question/clarification or the exercise of the said right, you may contact our office Data Protection Officer (the ‘’DPO’’) by using the information below.
Limassol Center B',
6th Floor, Off. 607,
Last Edited on 23rd May 2018