1. Introduction

GURICON LIMITED is committed to protecting the personal data of its employees, customers, suppliers and other stakeholders and to ensuring its compliance with all relevant legislation. As part of its business, GURICON LIMITED relies upon a number of third party organisations to assist in providing a high level of service to its customers, in offering complete suite of business solution to its clients, in ranging from tax planning, fiduciary services, consulting, administrative support and compliance, and in looking after its employees, amongst a wide range of other activities.

Guricon Limited consists of highly skilled professionals with many years of experience in International business and professional services in the form of taxation, management accounting and consulting, so Guricon Limited respect the trust and confidentiality of its clients, employees, suppliers and other stakeholders where them peace of mind is most upmost importance.

This procedure is intended to be used when a data subject exercises one or more of the rights they are granted under the European Union General Data Protection Regulation (GDPR).

Each of the rights involved has its own specific aspects and challenges to GURICON LIMITED in complying with them and doing so within the required timescales. In general, a proactive approach has been taken that places as much control over personal data in the hands of the data subject as possible, with a minimum amount of intervention or involvement required on the part of GURICON LIMITED.

2. Our Firm

When you become our client, you entrust us with your personal and financial data, and may entrust us with the custody of your assets as well. We recognize that our relationship is based on trust, and that you expect us to act responsibly and in your best interests. Because your personal and financial data is your private information, we hold ourselves to the highest standards in its safekeeping and use.

This means, most importantly, that we do not sell client information, whether it is your personal information or the fact that you are our client, to anyone. Instead, we use your information primarily to complete transactions and services that you request.

Protection of your privacy and the security of your personal data are very important to our Firm.

You typically provide personal information to us when you complete and sign the relevant questionnaire with us and before you sign the engagement letter as per AML regulations and/or legislations (Know your Client).

This Privacy Policy explains how information about you is collected and used by our Firm.

By using our website, providing personal information and/or using any of our services, you agree that:

• you consent to this Privacy Policy, as updated from time to time; and
• if you have provided personal information to us relating to any other person, you:
  (a) have a right to provide that information
  (b) have provided a copy of this Privacy Policy, as updated from time to time, to that person; and
  (c) each such person has agreed to those terms.

In such cases, references in this Privacy Policy to terms such as “you” and “your” also refer to such persons.

3. Definitions

Personal data: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

‘processing’: any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

‘controller’: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

4. What information do we collect ABOUT YOU?

For general web-browsing of this website, your personal data is not revealed to us, although certain statistical information is available to us via our internet service provider as well as through the use of special tracking technologies. Such information tells us about the pages you are clicking on or the hardware you are using, but not your name, age, address or anything we can use to identify you personally.

However, if you wish to use certain services offered on our website, obtain certain information made available by us, or request us to provide you with corporate or fiduciary services through our Contact Us page or by contacting our Team directly, then you may be asked for information such as full name, email address, telephone number, fax number and residential address.

If you enter into a business relationship with us, either as a client or as one of our business partners, vendors or suppliers, then the kinds of personal information that we collect and hold about you may include:

• identifying information, such as your full name, occupation, age, and any photographs found in your identity verification documentation;
• contact information, such as your email address, mailing address or phone number;
• records of our communications with you; and/or
• Information we may have obtained from other sources (such as risk intelligence service providers, lexis nexis) in order to identify who we are doing business with as part of the ‘know your clients’ obligations contained in relevant legislation.
• Information that you provide to us in a relation to your source and size of funds as part of the ‘know your clients’ obligations contained in relevant legislation.

In these cases the provision of your personal data will be a contractual requirement or a requirement relating to entering into a contract, and you will be obliged to provide the personal data we require in order to comply with our legal obligations and provide the services to you under that contract. Without this information, we may not be able to provide you with our services or to respond to queries or requests that you submit to us. You may, however, visit our website anonymously.

5. Why do we collect this information?

Legal grounds for processing

We always ensure we respect your privacy rights. This means we can only collect your personal data if we have lawful grounds for doing so. In most cases, we may rely on the following grounds:

• we may have a contractual arrangement with you and to fulfil our obligations we need to process your personal data (e.g. you are a client, external providers, third parties)
• there may be a legal obligation for us to process your personal data (e.g. so we can properly identify you and comply with relevant anti-money laundering legislation)
• we may want to fulfil a compelling legitimate interest we may have in a manner that does not outweigh your rights and freedoms (e.g. ensuring security of our IT infrastructure and systems, or monitoring the use and effectiveness of our website)
• you may have expressly asked us to do something or have otherwise given your clear consent to us that you are happy for us to process your data (e.g. for marketing purposes, or simply responding to a question you may have asked us or other feedback you may have given us)

In most cases, we collect personal data that you choose to provide to us so that we can provide you with a service you have requested from us such as establishment of a corporate organization for example. The relevant information is then used by us to communicate with you on any matter relating to the conduct of your instructions in general. Specifically, if you are a client, this would be providing the services agreed with you in accordance with our Terms and Conditions (as may be amended) and as necessary for the performance of our contract with you. If you choose not to provide certain information, we may not be able to provide you with some services.

Other reasons we may process your information include:

• maintaining our administrative or client relationship management systems;
• providing you with information about us and our range of services, otherwise known as ‘Direct Marketing’;
• management of enquiries and complaints;
• if you have applied for a job with us, so we can consider you for employment.
• if you are attending one of our events

We also process information relating to our employees, and prospective applicants, for general employment and recruitment purposes. These purposes will be disclosed in more detail at the time we collect personal data from such persons.

6. What do we do with this informationand how we used this information?

We use your information in a number of ways. When we use your personal information, we must do so lawfully. In every case, we will use your information for the purposes for which it was provided by you or lawfully obtained by us, and where such purposes change or cease to exist, we will inform you that we need additional information or shall erase your information in accordance with the retention policies described in this Privacy Policy.

This information may be used:

• to verify your identity when you are dealing with us, so we may satisfy our obligations with respect to crime (including tax evasion) prevention and detection, anti-money laundering, due diligence, as well as any other relevant legal or regulatory obligations we may be subject to;
• to carry out lawful obligations arising from contracts entered into between you and us and to provide you with the information and services that you have requested from us or otherwise process transactions on your behalf such as settling invoices payable by you to us or to third parties;
• to notify you about changes to our services or this Privacy Policy;
• as permitted by law or regulation, and as required by law or regulation, or as requested by government or regulatory authorities, for the protection of persons or property or to establish or exercise our legal rights or defend against legal claims, including to comply with anti-money laundering obligations;
• in connection with an acquisition, merger, restructuring, sale or other transaction involving all or any portion of our business or assets;
• to ensure that content from our website is presented in the most effective manner for you and for your device(s); and/or
• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, or otherwise as part of our efforts to keep our website safe and secure.

We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us to develop our website and our services. We may also provide such aggregate information to third parties. These statistics will not include information that can be used to identify you, as the information is anonymised and ‘deidentified’. More information is found in our Cookie Policy.

Direct Marketing

Your information may also be used to provide you with information about us and our range of services, otherwise known as ‘Direct Marketing’. To this end, we may use your information:

• to allow you to participate in interactive features of our services, when you choose to do so;
• to inform you about and manage your involvement with our services and events, including educational or corporate hospitality events
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, including making suggestions and recommendations to you and other users of our website about goods or services that may interest you or them; and/or
• to provide you, with news bulletins, newsletters, brochures, or general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, or otherwise feel may be of interest to you (unless you have opted-out of receiving such information).

In circumstances where you are an existing client or we otherwise have an existing relationship with you we will rely on our legitimate interests as the lawful ground for processing your personal data for direct marketing purposes. To this end, it may be necessary to process your personal data so we can directly market in our legitimate interest. In addition, we consider it reasonable for you to expect you may receive marketing material from us in the same methods we normally communicate with you (e.g. via email) and that there is no disproportionate impact to your individual privacy rights in this case.

In circumstances where you are not a client or we do not otherwise have an existing relationship with you, marketing our materials, events and services (or those of others) to you shall be subject to your consent which shall be requested at the latest on our first communication to you, where you will be given the option to elect to receive such information (known as ‘opting-in’) by checking the appropriate boxes on the forms we use to collect your data or in links provided within our email communications.

Please note that any administrative or service-related communications (to offer corporate or fiduciary services, or notify you of an update to this Privacy Policy or our Terms and Conditions etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, please be aware that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website or as part of a contractual relationship we may have with you.

If you wish to be removed, we will retain your details in our marketing database(s) specifically for the purposes of suppressing your details from inclusion in all future marketing campaigns. These database(s) are restricted for access only by members of our marketing team. Your unsubscription request will only affect these database(s) and will not change any existing information on our other databases that you have provided to us or we have otherwise obtained for the purposes of providing our services to you or for any other lawful purposes.

7. What rights do you have?

As from the 25th May 2018 the General Data Protection Regulation (Regulation (EU) 2016/679, more commonly known as the ‘GDPR’) gives data subjects (like you) more rights in relation to their personal data. You can find out more about the GDPR and your rights by accessing the European Commission’s website.

If you are a natural person (in other words, a human being and not a company) you have the right to:

• information about the processing of your personal data (and if you did not give it to us, information as to the source).
• obtain access to the personal data held about you.
• ask for incorrect, inaccurate or incomplete personal data to be corrected.
• request, in certain cases, that personal data be erased when it’s no longer needed or if processing it is unlawful.
• object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation.
• request the restriction of the processing of your personal data in specific cases.
• receive your personal data in a structured, commonly used and machine-readable format, or ask us to send it to another person (‘data portability’) and
• request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision.

Please note these rights may only apply in certain cases. For example, some rights only apply where our lawful ground of processing is your consent, or where we have a contract with you.

You also have a right to lodge a complaint with the appropriate data protection authority whose details are provided below, and in certain cases may receive compensation from us, as data controller, for any damage you suffer.

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address or name, please let us know the correct details by contacting us on the details below. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.

8. How can you access information we hold on you and enforce your rights?

You can enforce the rights described above by means of a written request to us at the contact details below. To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity and completion of a form so that we can better understand the nature of your request and the information you are after. You will need to provide information to confirm your identity so we are sure it is actually you requesting your data (and not someone else trying to steal it!). We must respond to your requests without undue delay and at the latest within 1 month.

There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases, we will let you know why we cannot comply with your request.

In addition, you can enforce your right to object to direct marketing as described in the Direct Marketing section above.

Even if you do not request access to and/or correct your personal information held by us, if we are satisfied that, having regard to the reasons for which we hold your personal information, that personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.

9. Whom might weshare your information with?

In certain cases we may access, preserve, and disclose to third parties information about you if we believe disclosure is in accordance with, or required by, any contractual relationship with you, applicable law, regulation or legal process, unless such information is protected by duties of confidentiality owed to our clients or to other persons. Personal data may be processed by us and/or our affiliates, agents, vendors, consultants or suppliers, as well as any other third party service providers who are performing certain services on our behalf for the purposes specified above (for example, our agents located in various jurisdictions where we do business who provide trust and corporate services similar to us, financial institutions, and/or relevant custodians and investment managers) or on your specific instructions (for example, where you ask us to transfer to another service provider your personal information and/or documents relating to an entity we manage or a service we have provided to you). Such third parties have access to personal data solely for the purposes of performing the services specified in our Terms and Conditions or to comply with applicable laws and not for any other purpose (unless you instruct us to transfer personal information and/or documents to another service provider, in which case that service provided shall be given such access to your personal data as you expressly authorise us to give or otherwise under any applicable contract you may have with them). We require these third parties to undertake security measures consistent with the protections specified in this Privacy Policy. Such third parties may be located within or outside of Cyprus.

In addition we may be required by law or by a court to disclose certain information about you or any contract we may have with you to relevant regulatory, law enforcement and/or other competent authorities, unless such information is protected by duties of confidentiality owed to our clients or to other persons. We may also need to share your information in order to enforce or apply our legal rights under our agreed Terms and Conditions.

Finally, if our business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.

Transport abroad

In connection with the provision of our services, personal data may also be transferred to countries or territories outside the European Economic Area (EEA) where necessary. For example if you ask us to establish a corporate vehicle outside of Cyprus as part of the services specified in our Terms and Conditions your data may be transferred to our agents and business partners in jurisdictions.

Further, in the context of international legal proceedings or cross-jurisdictional services, or other services you request from us, we may need to use other service providers located outside the EEA, such as legal or tax advisors. In which case we will arrange for contractual safeguards where such territories do not offer an adequate level of personal data protection similar to the EEA. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

We may also rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we may collect and transfer your Personal Data outside the EEA only: with your consent; to perform a contract with you; or to fulfil a compelling legitimate interest we may have in a manner that does not outweigh your rights and freedoms. For example, if you are settling an invoice via telephone then in order to effectively process credit or debit card transactions it may be necessary for our bank/card processing agency to verify your personal details for authorisation outside the EEA; in such a case, such information will not be transferred out of the EEA for any other purpose.

We do not sell your information

Communicating via the Internet and sending information to you by other means necessarily involves your personal information passing through or being handled by third-parties, but we do not sell or distribute without your permission your personal information to third parties for purposes of allowing them to market products and services to you. Any information we share with marketing companies, data analytics companies, website developers, and similar service providers and their affiliates is for the sole purpose of developing, hosting, managing, operating and supporting the content on our website, or otherwise improving our website and the manner in which we market Guricon Limited. We ensure that in such cases, the information cannot be used to identify you and is anonymised and ‘de-identified’. More information is found in our Cookie Policy.

10. How do wesecure your information?

We are committed to taking appropriate measures designed to keep your personal data secure. Our technical, administrative and physical procedures are designed to protect personal data and non-personal data from loss, theft, misuse and accidental, unlawful or unauthorised access, disclosure, alteration, use and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.

To prevent unauthorised access as required by the Data Protection Act, we follow strict security procedures in the storage and disclosure of information which you have given us. Our security procedures mean that we may request proof of identity before we are able to disclose personal data to you following a request from you for us to do so. We implement security measures across the firm to ensure our clients’ data is protected within secured and encrypted servers we control, which are located in Cyprus. We may also keep hard copy records of this personal information in physical storage facilities with access restricted solely to our personnel.

In order to improve the quality of our procedures in a matter of protection of your personal data and in order to avoid any leak based on the human error of our employees and/or data processors, we ensure and secure new method which will be the following: lock any document that will be exchanged through emails, so the document can only be unlocked through a secure code that we will provide to you.

We also take steps to monitor access to and modification of your information by our contractors, advisers, consultants and staff members, and ensure that they are aware of and properly trained in their obligations for managing your privacy.

We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

Our website does not collect your personal information and you may browse anonymously. More information is found in our Cookie Policy. If you have any further questions about the security of your personal information, you can contact us on the details below.

Risks of using the Internet

We use reasonable physical, electronic, and procedural safeguards to protect the personal information that we obtain from you from loss, misuse, and unauthorised access, disclosure, alteration, and destruction. Please note that we are not responsible for the security of any data you are transmitting over the Internet, or any data you are storing, posting, or providing directly to a third party’s website, which is governed by that party’s policies. Please note that no method of transmission over the Internet or method of electronic storage is 100% secure and we cannot ensure or warrant the security of any information you transmit to us. Transfer of your data via these means is therefore at your own risk.

Data Breaches

A loss of personal data is known as a data breach. The GDPR imposes requirements on businesses to identify, assess and report breaches in a timely manner (within 72 hours). We undertake to inform you if your personal data is compromised and there is a risk to your rights and freedoms as a result.

11. How long do we keep your information for?

Our retention policies

We shall retain a record of our engagement with all our clients, as well as all files and documentation relating to clients and/or the particular matter that forms the basis on the legislation for a minimum period of 5 (five) years from the end of the business relationship described in the relevant engagement documentation, unless:

• we are required by law to retain such records for a longer period;
• continued retention is necessary for the establishment, exercise or defence of legal claims; or
• in order to protect your vital interests or the vital interests of another natural person.

We will attempt to minimise personal data to what is necessary to identify the client and the services provided by Guricon Limited, and after the applicable retention period has expired shall destroy all personal data and other records. At our discretion, we may retain personal information for less than or longer than the said period of 5 (five) years if we consider it necessary or desirable to do so to meet our legal or regulatory obligations, or at your specific request (for example, if you ask us to retain certain documents).

For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us on the details provided below.

Information about you that is no longer necessary and relevant to provide our services may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to us, such as statistics of the use of our services or our main sources of work. This information will be de-associated with your name and other identifiers and the data will therefore be anonymised.

Likewise, certain statistical information obtained from our website is already anonymised. More information is found in our Cookie Policy. Such information may be kept by us for longer periods than those specified in this Privacy Policy, provided that such retention is in accordance with applicable laws and regulations.

12. How can you contact us or make a complain?

Contact information of Data Controller

The Data Protection Officer for any personal data you provide to us, is Ms. Thekla Smyrilli. If you have any questions, concerns or comments or if you would like further information about this Privacy Policy, how we handle your Personal Data, or otherwise wish to enforce your data protection rights please contact us at:

Thekla Smyrilli
Inomenon Ethnon 48,
GURICON HOUSE 6042 Larnaca, Cyprus

Email: thekla.smyrilli@nuevo.cy
Phone: (+00357)24821200
Fax:(+00357)24821201

Your right to complain

We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal information and think we may have breached any applicable privacy laws, or any other relevant obligation, you are encouraged to raise any complaints regarding the processing of personal data to us directly on the contact details above.

We will make a record of your complaint and refer it to our internal complaint resolution committee for further investigation. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Data Protection Commissioner under the Data Protection Act, which is presently the Cyprus Regulatory Authority (CRA). The CRA is responsible for ensuring that your rights and obligations are respected. The CRA is also competent to hear your complaints and may prohibit or restrict the processing of your personal data in certain cases. You may contact the GRA on the below details:

Cyprus Data Protection Commissioner
Cyprus Regulatory Authority
Τ.Θ. 23378, 1682 Nicosia
Email: commissioner dataprotection.gov.cy
Phone: (+00357) 22818456
Fax: (+00357) 22304565

13. Additional information

Links

Occasionally, at our discretion, we may include links to third party products, services or websites on our website. Please be aware that we are not responsible for the privacy practices of any third party sites, nor do we verify nor accept any responsibility or liability for their content. The privacy policies of others may differ significantly from our Privacy Policy. Therefore, we encourage you to read the privacy statement/policy of each and every website that collects personal data.

Governing Law and Jurisdiction

All issues regarding our website and Privacy Policy are governed by Cyprus law and are subject to the exclusive jurisdiction of the Cyprus courts.

No Waiver

Delay or failure on our part in enforcing any of our rights shall not constitute a waiver by us of our rights and remedies. If any part of this Privacy Policy is held to be invalid or unenforceable, the validity or enforceability of the remainder will not be affected.

Privacy Protections for Children Using the Internet

Protecting children's privacy is important to us. For that reason, we do not collect or maintain information on our website from those we actually know are under the age of 16, nor is any part of our website targeted to attract anyone under 16. We request that all visitors to our website who are under 16 not disclose or provide any personal data and discontinue use of our website.

Revisions to this Privacy Policy

On this website, you can always view the latest version of our Privacy Policy and our Cookie Policy. We may modify this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will provide notice of such changes, such as by sending an email notification, providing notice through our website or updating the ‘Last Updated’ date at the beginning of this Privacy Policy. The amended Privacy Policy will be effective immediately after the date it is posted. By continuing to access or use our website after the effective date, you confirm your acceptance of the revised Privacy Policy and all of the terms incorporated therein by reference. We encourage you to review the Privacy Policy whenever you access or use our website to stay informed about our information practices and the choices available to you. If you do not agree to the revised Privacy Policy, you may not access or use this website. If you are an existing client and do not agree to the revised Privacy Policy, your only option will be to terminate your relationship with us under our Terms and Conditions or other contractual arrangement that may be in place. Please contact us on the above details should you wish to enforce any of these rights.