Effective date: 25th May 2018
Introduction
We are committed to protect privacy of information and personal data entrusted to us.
Equation Corporate Services Limited (in this Privacy Notice, “Equation”, “us”, “we” and “our”) registered in Cyprus under registration number 310288 with registered office address at 4A Alexandrou Douma, Lakatamia, 2321 Nicosia, Cyprus is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”).
This Privacy Notice applies to personal data processed by Equation and explains how Equation collects, uses and discloses your personal data, and your rights in relation to the personal data it holds.
Our Privacy and Data Protection Officer (“DPO”) is Petroula Ioannou
Email – petroula.ioannou@equationcs.com
Telephone – +35722257680
Processing of your Personal data
We collect your personal data in a number of ways, for example:
- From the information you provide to us when you meet us;
- From information about you provided to us by your company or an intermediary;
- When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
- When you complete (or we complete on your behalf) application form or other forms (bank);
- From your agents, lawyers, intermediaries, and custodians of your assets;
- From publicly available sources or from third parties, most commonly where we need to conduct back ground checks about you.
We understand the importance of protecting children's privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children. For the purposes of this privacy statement, “children” are individuals under the age of eighteen.
The categories of personal data (Personally Identifiable Information)
We collect the following categories of personal data about you:
- Your name and contact information such as your home or business address, email address and telephone number; skype name
- Biographical information which may confirm your identity including your gender, family circumstances (marital status), date of birth, tax residency and tax identification number and your passport number and/or national identity card details, country of domicile and/or your nationality;
- Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;
- Information about your knowledge, education and professional experience, family or personal circumstances, and interests, where relevant;
- An understanding of your goals and objectives in procuring our services; and
- Information to assess whether you may represent a politically exposed person or money laundering risk.
The personal data that we may collect may also include ‘sensitive’ or ‘special categories’ of personal data, such as details about your health (for example, in relation to life and medical insurance), ethnic or racial origin. Please note that, when the processing of sensitive personal data is not allowed by law, an explicit consent from you will be required whenever we may have to obtain sensitive personal data about you so as to provide our services
Rights of Data subjects:
Under the GDPR you, a physical person, have the following rights:
- To obtain access to, and copies of, the personal data that we hold about you;
- To request the rectification of inaccurate data
- To require that we cease processing your personal data if the processing is causing you damage or distress;
- To require us not to send you marketing communications;
- To require us to erase (“right to be forgotten”) your personal data;
- To require us to restrict our data processing activities;
- To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
- To require us to correct the personal data we hold about you if it is incorrect.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
You can find out more about your rights at www.dataprotection.gov.cy (link to website of the Office of the Commissioner for Personal Data Protection, the local regulatory authority.) If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact us using the following:
By post - Equation Corporate Services Ltd | 30 Chytron, 2nd floor, office A22, 1075 Nicosia, Cyprus
By email – petroula.ioannou@equationcs.com
By telephone - +35722257680
If you are not satisfied with how we are processing your personal data, you can make a complaint to the Office of the Commissioner for Personal Data Protection in Cyprus, at www.dataprotection.gov.cy.
The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with
We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(i) Performance of a Services agreement with you
We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into an agreement. If you do not provide the personal data we request from you, we may not be able to offer or continue offering our services to you.
In this respect, we use your personal data for the following:
- To prepare a proposal for you regarding the services we offer;
- To provide you with the services as set out in Application form and Services Agreement with you or as otherwise agreed with you from time to time;
- To deal with any complaints or feedback you may have;
- For any other purpose for which you provide us with your personal data.
In this respect, we may share your personal data with or transfer it to the following:
- Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
- Third parties whom we engage to assist in delivering the services to you,
- Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
- Other third parties such as intermediaries and banks who we introduce to you. We will wherever possible tell you who they are before we introduce you;
- Our data storage providers.
(ii) Legitimate interests
We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person. In this respect, we use your personal data for the following:
- For marketing to you. In this respect, see the separate section on Marketing below;
- Training our staff or monitoring their performance;
- For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
- Seeking advice on our rights and obligations, such as where we require our own legal advice;
In this respect we will share your personal data with the following:
- Our advisers or agents where it is necessary for us to obtain their advice or assistance;
- With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
(iii) Legal obligations
We are required to comply with certain legal and regulatory obligations, as well as certain industry standards, which may involve the processing of personal data. We may, for example, need to carry out identity verifications through our “know-your-client” procedures, set-up anti-money laundering controls and comply with our tax reporting obligations. We may also need to provide information to a public body or law enforcement agency when we are so required.
In this respect, we will share your personal data with the following:
- Our advisers where it is necessary for us to obtain their advice or assistance;
- Our auditors where it is necessary as part of their auditing functions;
- With third parties who assist us in conducting background checks;
- With relevant regulators or law enforcement agencies where we are required to do so.
Marketing
We will send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.
We will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels.
You may withdraw your consent to such processing at any time by contacting info@equationcs.com or clicking on the “Unsubscribe” function in any marketing communications, including emails, that we send to you.
Transfer and processing of your personal data outside the European Union
When sharing your personal data with third parties as set out in this Privacy Notice, it may be transferred outside the European Union. In these circumstances, your personal data will only be transferred on one of the following bases:
- the country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;
- the transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
- the recipient has entered into European Commission standard contractual clauses with us; or
- you have explicitly consented to the same.
To find out more about transfers by us of your personal data outside the European Union and the countries concerned please contact us:
By post - Equation Corporate Services Ltd | 30 Chytron, 2nd floor, office A22, 1075 Nicosia, Cyprus
By email – petroula.ioannou@equationcs.com
By telephone - +35722257680
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
- technological security measures, including fire walls, encryption and anti-virus software; and
- physical security measures, such as staff security passes to access our premises
Retention of your data
In particular:
where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for five years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or
otherwise, we will in most cases retain your personal data for a period of six years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date at the top of the first page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.