Privacy statement

1. PURPOSE OF THIS STATEMENT

PPP Global Consultants (Cyprus) Ltd (“ referred to as “we”, “us”, “our” “ours” or ‘Global Consultants’) is committed to ensuring the protection of the privacy and security of any personal data that we collect and process.

This statement describes how we collect and use personal data about you and informs you about your rights in accordance with the local data protection law and the EU General Data Protection Regulation (GDPR).

This statement is directed to natural persons who are either current or potential clients of Global Consultants and directors, authorised signatories, secretaries, shareholders and beneficial owners of legal entities which are either current or potential clients of Global Consultants.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. ABOUT US

Global Consultants is a licenced corporate service provider registered in Cyprus as a limited liability company under number HE285264 and our registered office is at 5-7 Griva Digeni Street, G&S Court, 4th Floor, Office 401, 6030 Larnaca.

We have appointed a Data Protection Officer (DPO) who is responsible for assisting with enquiries in relation to this privacy statement or our treatment of your personal data. Should you wish to contact our Data Protection Officer you can do so using the contact details noted at paragraph 19 (Contact Us), below.

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We collect and process different types of personal data about you, for example, when:

• you request a proposal from us in respect of the services we provide;
• you or your representative engages us to provide our services and also during the provision of those services;
• you contact us by email, telephone, post or social media (for example when you have a query about our services); or
• from third parties such as business associates and/or publicly available resources such as the Department of Registrar and Official Receiver, Government Authorities, Financial Institutions, commercial registers, credit reference agencies, the press, media and the internet

4. THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include the following:

• your personal details (such as your name and address);
• details of contact ( telephone, e-mail) in relation to the provision, or the proposed provision, of our services;
• birth date, place and country of birth, marital status, employed/self-employed, if you hold a prominent public function ( for PEPs), FATCA/CRS info, authentication data ( e.g. signature), bank reference
• Current income and expenses, employment history, property ownership, employment position, source and size of wealth, source of funds, tax residence and tax ID, business partners details, copies of business agreements, contracts, invoices
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• Information we receive from other sources, such as publicly available information, or information provided from our business associates
• Information we receive from Financial Institutions and various Government Authorities

5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

• We may process your personal data for purposes necessary for the performance of our contract of services with you and to comply with our legal and ethical obligations as members of the Institute of Certified and Public Accountants of Cyprus (ICPAC).

• We may process your personal data for the purposes necessary for the performance of our contract of services with our clients. This may include processing your personal data whether you are an employee, subcontractor, supplier or customer of our clients.

• We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

• We may process your personal data for certain additional purposes with your consent. In these limited circumstances where your consent is required for the processing of your personal data, then you have the right to withdraw your consent for such specific purposes. However, any processing of personal data prior to the receipt of your revocation will not affect the lawfulness of the processing.

• Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

•  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 is necessary for the required client acceptance, 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, officer of the company beneficial owner.

If you refuse or are not able to provide us with information when requested, we will not accept you as client. Furthermore, we will not be able to perform the contract of services we have entered into with you and we may not be able to comply with our legal, code of conduct and regulatory obligations.

•  Situations in which we will use your personal data

• To carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
• To carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• To comply with legal obligations. There are a number of legal obligations emanating from the relevant laws to which we are subject to comply as well as statutory requirements, e.g. the Money Laundering Law and Tax laws. There is also a supervisory authority (Institute of Certified and Public Accountants- ICPAC), of which we are members, whose policies and regulations we are obliged to follow. Such obligations and requirements impose on us necessary personal data processing activities for identity verification, tax laws and regulations, KYC procedures, other reporting obligations and anti-money laundering compliance.
• To provide you with information related to our services and our events and activities that you request from us or which we feel may be of interest to you, provided you have consented to be contacted for such purposes;
• To seek your thoughts and opinions on the services we provide; and
• To notify you about any changes to our services.
In some circumstances where there is no legal or other regulatory obligation we may anonymise or pseudonymise your personal data so that it can no longer be associated with you. In such a case we may use it without further notice to you.

• Data retention

We will retain your personal data for as long as is necessary to fulfill the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

• Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use it where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before commencing any new processing.

6. DATA SHARING

• Why should you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us in accordance with our contract of services or where we have another legitimate interest or obligation in doing so.

• Which third-party process my personal data?

“Third parties” includes service providers and other entities within our Group and:

• Supervisory and other regulatory and public authorities, inasmuch as a statutory obligation exists. Some examples are the Institute of Certified and Public Accountants (ICPAC), the income tax authorities, Department of Registrar and Official Receiver, Social Security and other Government offices
• Credit and financial institutions
• For our anti-money laundering process, such as credit reference agencies etc
• External legal consultants
• Registered Agents
• For financial crime government department i.e MOKAS
• Other third parties after receiving your written approval

Third parties are required to take commercially and legally reasonable and appropriate security measures to protect your personal data. We only permit third parties to process your personal data for specified purposes and in accordance with our instructions and legal regulations.

7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We will transfer the personal data we collect about you outside of the EEA in order to perform our contract of services with you or when 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.

8. 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 may process some of your data automatically, with the goal of assessing certain personal aspects (profiling), in order to enter into or perform a contract of services with you, in the following cases:
• Data assessments (including payment transactions)
• Risk profiling

Both processes are carried out in the context of combating money laundering, fraud, terrorist financing and other criminal activities. A bank account may be detected as being used in a way that is unusual for you or your business. These measures also serve to protect you.

9. DATA SECURITY

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

10. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

• Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

• Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

11. Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.

12. Request correction of the personal data that we hold about you.

13. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

14. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.

15. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

16. Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our Data Protection Officer at [email protected].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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 is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

17. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose {for example, in relation to informative material (newsletters) that you have indicated you would like to receive from us}, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer at [email protected] .

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

18. CHANGES TO THIS statement

Any changes we may make to our privacy statement in the future will be updated on our website at:  www.globalconsultantgroup.net

This privacy statement was last updated on 12/06/2018

19. CONTACT US

If you have any questions regarding this statement or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Officer at [email protected].

You also have the right to make a complaint to the Office of the Commissioner for Personal Data Protection. You will need to visit their website and find out how to submit a complaint (http: //www.dataprotection.gov.cy).