Privacy & Cookie Policy

This policy applies to CorpZone Services Ltd and its affiliated companies (collectively “CorpZone”). This Privacy Policy describes how CorpZone handles and protects your personal information in connection with the hosting of this website, and the provision of its business advisory services (“Services”), as explained in more detail at: corpzonecy.com. Please note that the Website is not intended for persons under the age of 18.

1. Scope of this policy

This policy applies to personal information which is collected and/or used by CorpZone in its capacity as a controller as that term is defined in the EU data protection laws. The contexts in which this might occur are explored under “When do we collect personal information?” below. When we provide Services to clients, we sometimes handle personal information as a processor. This means that we process the information solely on the instructions of our clients, who retain control of the information. Therefore, if our use of your personal information is not covered by this policy, you may need to contact the client (and controller) on whose behalf the processing of your information is carried out. If CorpZone uses your personal information, you may have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why CorpZone uses your information. The primary point of contact at CorpZone for questions regarding your personal information is

2. Who is your controller?

The CorpZone responsible for your personal information will be the entity that originally collected information from or about you. Controller in accordance with Article 4 Clause 7 of the EU General Data Protection Regulation (GDPR) is CorpZone Services Ltd 6, Vasili Vryonides Str, Gala Court Chambers, 5th floor, 3095 Limassol, Cyprus +35797607031, assistant@corpzonecy.com.

3. Your Acceptance

In respect of personal information collected over this and other CorpZone websites, your continued use of these websites constitutes your understanding of, and agreement to, the practices described in this Privacy Policy and elsewhere on the websites as well as any subsequent updates.

4. When do we collect personal information?

We collect information about you if:

  • you use this website;
  • you enquire about, or engage CorpZone to provide, its Services (either in a personal capacity, or as a representative for your employer or client);
  • the use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
  • you apply for a position with CorpZone;
  • you contact us with any other enquiry, complaint or notice.

 

5. What types of personal information are collected and what do we use it for?

The following is a summary of the types of personal information we collect, and the purposes for which that information is used.

5.1. Website Users

CorpZone collects your name, address, e-mail address, telephone number and any other personally-identifiable information which you voluntarily provide as “comments” when you submit an inquiry through the “Contact Us” tool. CorpZone may also automatically collect personal information (through the use of Cookies or similar technologies, including your IP address, device identifier, browsing patterns on its websites, click stream data, and HTP protocol elements) to ensure the effective operation of the website or in order to align the presentation of our Services more closely to your requirements (for example, processing information about your broad geographic location to serve you with a local version of this website). This tracking information is stored in an anonymous, aggregated and non-personal format, and is also used to understand and analyze trends, to administer the websites, and to learn about user behavior on the websites. Please refer to our Cookie Policy for a more detailed overview on how CorpZone uses Cookies. In certain instances, CorpZone may use IP addresses to help identify you when CorpZone feels, in its sole discretion, that it is necessary to enforce compliance with this Privacy Policy, to protect its services, websites, systems, information, employees, business partners, subsidiaries, affiliates, users, customers or others, or when required by law or for law enforcement purposes.

5.2. CorpZone’s Former, Current and Prospective Clients

If you submit an enquiry to CorpZone about our Services (either over the website, or by emailing, telephoning or meeting with one of our colleagues), then we will process information such as your name, job title and contact information in order to respond to your enquiry. If you or the organisation you are associated with becomes a CorpZone client, then we may process your personal information in order to:

  • carry out “Know Your Client” checks and screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage);
  • carry out background checks for the purposes of complying with anti-money laundering and terrorist financing laws;
  • carry out client communication, service, billing and administration;
  • deal with client complaints;
  • and administer claims.
  • Taking account of applicable marketing laws, we also process personal information about our clients (former, current and prospective) in order to:
    • send our clients newsletters, know-how, promotional material and other marketing communications;
    • invite our clients to events (and arrange and administer those events).

 

6. What is our legal basis for collecting personal information?

All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:

  • the processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where you request certain Services as an individual client, or where we help advise your employer or service provider on fulfilling an obligation to you under a contract);
  • the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or the processing is necessary for the performance of a task carried out in the public interest (e.g. background checks for anti-money laundering and terrorist financing purposes); or
  • the processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal information in connection with the provision of our Services, and also for the purposes of most client on-boarding, administration and relationship management activities).

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required by applicable law to obtain your prior consent in order to send you marketing communications.
Before collecting and/or using any special categories of data (as that term is defined in the GDPR), or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:

  • your explicit consent;
  • the establishment, exercise or defence by us or third parties of legal claims; or
  • other uses allowed by applicable law including context specific exemptions provided for under local laws of EU

Member States and other countries implementing the GDPR, such as in relation to the processing of special category data for the purposes of preventing or detecting fraud in relation to instructions from potential clients.

7. Disclosure of Personal Information to Third Parties

CorpZone will not disclose your personal information to third parties other than as described in this Privacy Policy unless CorpZone has your permission or is required or permitted by law. CorpZone may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied or collected. Similarly, third party contractors, consultants and/or vendors engaged by CorpZone to provide services may have access to your personal information. These third parties will be subject to their own data protection requirements providing the same or greater level of security provided by CorpZone and in most instances will also have entered into a written agreement with CorpZone which addresses the protection of your personal information. CorpZone may also disclose your personal information for the purposes of:

  • responding to requests from law enforcement agencies, regulators or courts, or to subpoenas, search warrants, or other legal requests;
  • the prevention and/or detection of crime;
  • establishing legal rights or to investigate or pursue legal claims;
  • a merger, acquisition or corporate restructuring to which CorpZone is subject;
  • preventing risk of harm to an individual.

 

8. International Hosting and Transfer of Information

CorpZone may transfer certain personal information collected on its websites across geographical borders to CorpZone offices, personnel, or third parties located throughout the world. CorpZone may also store such information in a jurisdiction other than where you are based including outside of the European Economic Area (“EEA”).

CorpZone will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.

  • Where we transfer your personal information outside CorpZone to third parties who help provide us with any of the activities described in this policy, we obtain contractual commitments (such as the Standard Contractual Clauses) from them in order to protect your personal information.
  • Where we receive requests for information from law enforcement, courts or regulators (who may be based overseas), we carefully validate these requests before any personal information are disclosed.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

9. Protection of Personal Data

CorpZone has reasonable technical safeguards, security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Measures we take include placing confidentiality requirements on our staff members and service providers, limiting access to your personal information on a “need to know” basis, and providing training to appropriate CorpZone personnel. Despite CorpZone’s best efforts, however, security cannot be absolutely guaranteed against all threats.

10. Retention of your personal information

CorpZone retains your personal information for the period of time required for the purposes for which it was collected, any compatible purposes which we subsequently establish, or any new purposes to which you subsequently consent, or to comply with legal, regulatory and CorpZone policy requirements.

This period of time will usually be the period of your, or the relevant client’s, relationship or contract with CorpZone plus a period reflecting the length of time for which legal claims may be made following the termination of such relationship or contract. Some information (such as call recordings, tax records and certain information required to demonstrate regulatory compliance) may need to be kept for longer. Personal information will be kept for a shorter or longer period of time if so required by law or an CorpZone policy, if the information becomes subject to a legal hold (for example, following a communication from our regulator) or if we have identified through a data protection impact assessment that a different retention period is appropriate.

11. Your EEA Rights

Your personal information is processed by a CorpZone in the EEA, therefore it is subject to certain exemptions, and dependent on how and why we use it, you have certain rights in relation to your personal information. We may ask you for additional information to confirm your identity before disclosing any personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

11.1 Right to Access

You have the right to access personal information which CorpZone holds about you, together with certain information about how and why your personal information is processed.

11.2 Right to Rectification

You have a right to request us to correct your personal information where it is inaccurate or out of date.

11.3 Right to be Forgotten (Right to Erasure)

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.

11.4 Right to Restrict Processing

You have the right to restrict the processing of your personal information, but only where:

  • its accuracy is contested, to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

11.5 Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. Please note that CorpZone rarely relies upon consent as a legal basis, and the performance of a contract basis will only be relevant to the extent that you, as an individual, are party to a contract with CorpZone or a client, and our use of your personal information is necessary for the performance of that contract.

11.6 Right to Object to Processing

You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

12. Marketing

CorpZone may send you information related to its services, products and events that we believe are of interest to you. This information may be sent by post or via email. If at any point you no longer prefer to receive marketing communications from CorpZone you can (i) unsubscribe from CorpZone communications sent by email using a link provided in marketing emails sent from CorpZone; or (ii) contact us to exercise your right to prevent all forms of marketing (both post and email).

13. Links

CorpZone websites may contain links to other sites, including websites maintained by CorpZone affiliates that are governed by other privacy policies that may differ somewhat from this one. Users should review the privacy policy of each website visited before disclosing any personal information. CorpZone is not responsible or liable for your use of such third party websites.

14. Use of Cookies

A “cookie” is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the Site. We use cookies on the Site to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Site, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Site is being used and improve your user experience.

15. Types of Cookies

The following types of cookies may be used when you visit the Site:

Advertising Cookies
Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.

Analytics Cookies
Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.

Our Cookies
Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.

Personalization Cookies
Personalization cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.

Security Cookies
Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.

Site Management Cookies
Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

Third-Party Cookies
Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

 17. Control of Cookies

Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site.

For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies, or visit the following links:

  • Apple Safari
  • Google Chrome
  • Microsoft Edge
  • Microsoft Internet Explorer
  • Mozilla Firefox
  • Opera
  • Android (Chrome)
  • Blackberry
  • Iphone or Ipad (Chrome)
  • Iphone or Ipad (Safari)

In addition, you may opt-out of some third-party cookies through the Network Advertising Initiative’s Opt-Out Tool.

17. Other Tracking Technologies

In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Site to help customize the Site and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.

18. Changes to this Policy

By using CorpZone websites you consent to the collection, use and storage of personal information as described in this Privacy Policy and elsewhere on the websites. CorpZone reserves the right to make changes to this Website Privacy Policy from time to time. CorpZone will notify you by posting amendments to the Privacy Policy on this website.

19. Contact Us

If you have questions or concerns regarding this policy or CorpZone’s personal data processing policies, please contact CorpZone at: assistant@corpzonecy.com

 

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