Potens Corporate Privacy Policy

Introduction

POTENS CORPORATE SERVICES LTD values your personal and confidential information. We are committed to protecting this information with adequate protection and using it only for the purposes stipulated in the Potens Corporate Privacy Policy.

This Potens Corporate Privacy Policy (“Policy”) sets out the basis on which POTENS CORPORATE SERVICES LTD (“we”, “us”, “our”), with registration number HE411943, being a Data Controller, collects and processes your personal information, i.e. information collected online and offline, in accordance with the General Data Protection Regulation (2016/679) and the applicable Data Protection Laws of the Republic of Cyprus (“the Law”).

This Policy applies to all Personal Data in our possession or under our control.

Definitions of Terms Used in Policy in Potens Corporate Privacy Policy

“Data Controller” means the person or organization which determines when, why and how to process Personal Data and implements appropriate technical and organizational measures to comply with the Law;

“Data Processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller;

“Data Protection Officer” means the person who is formally appointed with the purpose of ensuring that we are aware of and comply with our data protection responsibilities and obligations according to the Law;

“Data Subject” means a living, identified or identifiable natural person about whom we hold Personal Data;

“Personal Data” means data about the Data Subject who can be identified:

a. from that data; or

b. from that data and other information to which we have or are likely to have access.

The Personal Data we may collect and use includes, without limitation, names and identification information such as email address, telephone numbers, copy of your passport and utility bill.

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Special Categories of Personal Data” means the information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

For the purposes of this Potens Corporate Privacy Policy, Personal Data includes Special Categories of Personal Data.

“Third Party” means the recipient of your Personal Data as defined below.

The Kind of Information We Collect About You

The purpose of the Processing of your Personal Data based on Potens Corporate Privacy Policy is largely based on each of our services that you have requested:

  • Contact details: e.g. name, email address, physical address, phone number etc.;

  • Demographic information: e.g. nationality, gender, age etc.;

  • Personal correspondence: e.g. emails that you send to us etc.;

  • Anti-Money Laundering and Combating Financing Terrorism (AML-CFT) compliance: e.g. identification documents and Know Your Client (KYC) documents, such as copies of your passports, utility bills, CVs and reference letters;

  • Any additional information that may be necessary for the provision of particular services.

In the event that you provide us with Personal Data about other individuals, e.g. your colleague or client, you warrant to us that you have obtained such individuals’ permission to do so.

We do not collect or process Personal Data of children without prior consent from their parents or legal guardian.

Why Do We Process Your Personal Data?

The purpose of the Processing of your Personal Data is largely based on each of the services that you have requested or that have been agreed with you. In general, your Personal Data is processed within the scope of our business relationship with you.

On What Legal Basis Do We Process Your Personal Data?

We may collect and process your Personal Data for any and/or all the following purposes:

  1. We may have a contractual arrangement with you, and we need to process your Personal Data in order to fulfil our obligations, e.g. you are a client;

  2. There may be a legal obligation for us to process your Personal Data, e.g. compliance with relevant anti-money laundering legislation;

  3. We may want to fulfil a legitimate interest pursued by us or by a third party, in a manner that does not override your rights and freedoms;

  4. You may have expressly asked us to do something or have otherwise given your clear consent to us to process your Personal Data, e.g. responding to a question you may have asked us.

Who Receives Your Personal Data?

Your Personal Data may sometimes be shared or made accessible to the following Third Parties in order for us to perform our services to the highest standard possible:

  1. Employees who need access to fulfil the purposes set out above;

  2. Service providers, including but not limited to IT service providers that support our services;

  3. Financial Institutions;

  4. Public Authorities, e.g. Registrar of Companies;

  5. Payment Service Providers.

In the absence of your consent, your Personal Data will not be disclosed to any Third Party, other than those mentioned above, unless the disclosure is required and/or mandatory under the provisions of any legislation, regulation or upon a request from a governmental, supervisory or competent authority.

Our employees have signed a Confidentiality and Non-Disclosure Agreement.

When we enter into an agreement with a Third Party that requires your Personal Data to be processed by that Third Party, we enter into a processing agreement with that party in order to ensure that they process the Personal Data strictly according to our instructions and implement the appropriate administrative, physical and technical measures to protect the Personal Data from unauthorized or accidental use, collection, access, damage, loss or disclosure.

Transferring Your Personal Data Outside the European Union (“EU”) and/or European Economic Area (“EEA”)

We generally do not transfer Personal Data to countries outside the EU and/or EEA (“Third Countries”), except where required by the purposes set out in this Policy.

If we need to transfer your Personal Data to Third Countries for any other purpose, we always ensure that the transfer meets the relevant requirements of the Law, and we take all steps required to ensure that your Personal Data continues to receive our standards of protection.

When Can Personal Data Be Transferred Outside the EU and the EEA?

Personal Data may be transferred outside the EU and the EEA:

  • If the European Commission has made a finding that the third country, territory or sectors within the third country ensure an adequate level of privacy protection (“Adequacy Decision”);

  • If the Third Party has signed the standard data protection clauses, i.e. a contract, adopted by the European Commission and agreed to apply the privacy standards of protection of the European Union;

  • If the Data Subject has provided consent to the transfer.

How Long Will We Store Your Personal Data?

We will cease to retain your Personal Data or remove the means by which the Personal Data can be associated with you after seven (7) years where your relationship with us has been terminated and/or as soon as it is reasonable to assume that such retention no longer serves the purposes for which the Personal Data was collected and is no longer necessary for legal or business purposes, except where retention is permitted or required by the Law and/or other applicable laws.

Protection of Personal Data in Potens Corporate Privacy Policy

To safeguard your Personal Data from unauthorized access, collection, use, damage, loss, disclosure, copying or similar risks, Potens Corporate Privacy Policy have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data to Third Parties.

We also allow access to Personal Data only to those employees who need to know such data, and they will only process your Personal Data on our instructions.

However, no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we try to protect the security of the Data Subject’s Personal Data and constantly review and enhance our information security measures.

What Are Your Rights in Relation to Your Personal Data?

Right to Access

You may request access to your Personal Data, commonly known as a “data subject access request.” This enables you to receive a copy of the Personal Data that we hold about you at any time.

Right to Rectification

You may request that we correct or update any of your Personal Data which we hold. This enables you to have any incomplete or inaccurate information we hold about you corrected. We strive to retain only Personal Data that is accurate, complete and up to date.

Right to Data Portability

You may request the transfer of your Personal Data to another party.

Right to Erasure based of Potens Corporate Privacy Policy

You may request that we delete your Personal Data from our records. However, we may need to retain certain information for legal or administrative purposes, such as record keeping and detecting fraudulent activities.

Right to Restrict Processing

You may request that we restrict the use of your Personal Data.

Right to Object

You have the right to object to the collection and use of your Personal Data. For example, when we use your Personal Data on the basis of your consent, you can withdraw that consent at any time.

Right to Lodge a Complaint

You have the right to lodge a complaint about the use of your Personal Data by contacting the Office of the Commissioner for Personal Data Protection in Cyprus using the contact details below:

Office address: Iasonos 1, 1082 Nicosia, Cyprus

Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus

Tel: +357 22818456

Fax: +357 22304565

Email: commissionerdataprotection.gov.cy

Exercising Your Rights

If you wish to exercise any of your rights, you may contact our Data Protection Officer in writing or via email using the contact details provided below:

Address: 58 Raphael Santi, Nefeli Court 11, Ground Floor, 6052 Larnaca, Cyprus

Email: Data Protection Officer at dpo@toulouraslaw.com

The Data Protection Officer has the right to require the individual making the request to provide certain identification documents or information to verify their identity.

The Data Protection Officer of Potens Corporate Privacy Policy will respond to your request within thirty (30) days after receiving your email or letter.

How Do We Protect Your Personal Data?

To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying or similar risks, we have introduced appropriate administrative, physical and technical measures.

You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we try to protect the security of Personal Data by constantly reviewing and enhancing our information security measures.

Effect of Policy and Changes to Policy

We keep the Potens Corporate Privacy Policy under review and may modify it from time to time without prior notice. You should review this Policy on our website periodically to ensure that you are aware of any modifications or updates.

Cookies Policy

Our website uses cookie technology. Cookies are small files saved to your computer or mobile device that track, save and store information, as well as your interactions with and use of our website.

The primary purpose for collecting data from users of our site is to allow us to provide a smooth, efficient and personalized experience while using our site.

Users are advised that if they wish to deny the use and saving of cookies from this website onto their computer’s hard drive, they should take the necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors.

We also collect other forms of non-personal information, such as browsers used to access our website, search terms used to find the website, traffic referrals and links to our website.

Cookies collected by us are used to enable certain functions and tools of our website, assist in the navigation of the website, track resources and data used on this site, and remember computer settings.

You may prevent your computer from accepting cookies by modifying the properties of your web browser. Please see your browser’s “Help” option for information on how to do this.

We also use the services of Google Analytics software to analyze traffic to our website. Neither of these programs creates individual profiles for visitors, nor do we collect any personally identifiable information using these services.

Data collected regarding site usage is compiled in aggregate to improve the performance of the website. If you do not wish your information to be included in this aggregated data through Google Analytics, modify the properties of your web browser to prevent your computer or mobile device from accepting cookies. Please read the Google Privacy Policy for further information.

Types of Cookies

Strictly Necessary Cookies

These cookies are necessary for the website to enable you to use certain features, such as requesting specific services, setting your privacy preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Functionality Cookies

These cookies are used to allow the website to remember choices you make, such as language preferences, and provide enhanced features to improve your web experience.

Navigation Cookies

These cookies enable the site to function correctly and are used to gather information about how visitors use the site.

This information is used to compile reports and help us improve the site. Cookies gather information anonymously, including the number of visitors to the site, where visitors came from and the pages they viewed.

Analytical Cookies

These cookies are used to produce statistical analyses of the way users navigate the site using computers or mobile devices, the number of pages viewed and the number of clicks made on a page during navigation of the site.

Disabling Cookies

You can prevent cookies from being set by adjusting the settings on your browser. Please see your browser’s “Help” option for information on how to do this.

Be aware that disabling cookies may affect the functionality of this and other websites that you visit. Potens Corporate Privacy Policy

Introduction

POTENS CORPORATE SERVICES LTD values your personal and confidential information. We are committed to protecting this information with adequate protection and using it only for the purposes stipulated in the Potens Corporate Privacy Policy.

This Potens Corporate Privacy Policy (“Policy”) sets out the basis on which POTENS CORPORATE SERVICES LTD (“we”, “us”, “our”), with registration number HE411943, being a Data Controller, collects and processes your personal information, i.e. information collected online and offline, in accordance with the General Data Protection Regulation (2016/679) and the applicable Data Protection Laws of the Republic of Cyprus (“the Law”).

This Policy applies to all Personal Data in our possession or under our control.

Definitions of Terms Used in Policy

“Data Controller” means the person or organization which determines when, why and how to process Personal Data and implements appropriate technical and organizational measures to comply with the Law;

“Data Processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller;

“Data Protection Officer” means the person who is formally appointed with the purpose of ensuring that we are aware of and comply with our data protection responsibilities and obligations according to the Law;

“Data Subject” means a living, identified or identifiable natural person about whom we hold Personal Data;

“Personal Data” means data about the Data Subject who can be identified:

a. from that data; or

b. from that data and other information to which we have or are likely to have access.

The Personal Data we may collect and use includes, without limitation, names and identification information such as email address, telephone numbers, copy of your passport and utility bill.

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Special Categories of Personal Data” means the information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

For the purposes of this Potens Corporate Privacy Policy, Personal Data includes Special Categories of Personal Data.

“Third Party” means the recipient of your Personal Data as defined below.

The Kind of Information We Collect About You

The purpose of the Processing of your Personal Data is largely based on each of our services that you have requested:

  • Contact details: e.g. name, email address, physical address, phone number etc.;

  • Demographic information: e.g. nationality, gender, age etc.;

  • Personal correspondence: e.g. emails that you send to us etc.;

  • Anti-Money Laundering and Combating Financing Terrorism (AML-CFT) compliance: e.g. identification documents and Know Your Client (KYC) documents, such as copies of your passports, utility bills, CVs and reference letters;

  • Any additional information that may be necessary for the provision of particular services.

In the event that you provide us with Personal Data about other individuals, e.g. your colleague or client, you warrant to us that you have obtained such individuals’ permission to do so.

We do not collect or process Personal Data of children without prior consent from their parents or legal guardian.

Why Do We Process Your Personal Data?

The purpose of the Processing of your Personal Data is largely based on each of the services that you have requested or that have been agreed with you. In general, your Personal Data is processed within the scope of our business relationship with you.

On What Legal Basis Do We Process Your Personal Data?

We may collect and process your Personal Data for any and/or all the following purposes:

  1. We may have a contractual arrangement with you, and we need to process your Personal Data in order to fulfil our obligations, e.g. you are a client;

  2. There may be a legal obligation for us to process your Personal Data, e.g. compliance with relevant anti-money laundering legislation;

  3. We may want to fulfil a legitimate interest pursued by us or by a third party, in a manner that does not override your rights and freedoms;

  4. You may have expressly asked us to do something or have otherwise given your clear consent to us to process your Personal Data, e.g. responding to a question you may have asked us.

Who Receives Your Personal Data?

Your Personal Data may sometimes be shared or made accessible to the following Third Parties in order for us to perform our services to the highest standard possible:

  1. Employees who need access to fulfil the purposes set out above;

  2. Service providers, including but not limited to IT service providers that support our services;

  3. Financial Institutions;

  4. Public Authorities, e.g. Registrar of Companies;

  5. Payment Service Providers.

In the absence of your consent, your Personal Data will not be disclosed to any Third Party, other than those mentioned above, unless the disclosure is required and/or mandatory under the provisions of any legislation, regulation or upon a request from a governmental, supervisory or competent authority.

Our employees have signed a Confidentiality and Non-Disclosure Agreement.

When we enter into an agreement with a Third Party that requires your Personal Data to be processed by that Third Party, we enter into a processing agreement with that party in order to ensure that they process the Personal Data strictly according to our instructions and implement the appropriate administrative, physical and technical measures to protect the Personal Data from unauthorized or accidental use, collection, access, damage, loss or disclosure.

Transferring Your Personal Data Outside the European Union (“EU”) and/or European Economic Area (“EEA”)

We generally do not transfer Personal Data to countries outside the EU and/or EEA (“Third Countries”), except where required by the purposes set out in this Policy.

If we need to transfer your Personal Data to Third Countries for any other purpose, we always ensure that the transfer meets the relevant requirements of the Law, and we take all steps required to ensure that your Personal Data continues to receive our standards of protection.

When Can Personal Data Be Transferred Outside the EU and the EEA?

Personal Data may be transferred outside the EU and the EEA:

  • If the European Commission has made a finding that the third country, territory or sectors within the third country ensure an adequate level of privacy protection (“Adequacy Decision”);

  • If the Third Party has signed the standard data protection clauses, i.e. a contract, adopted by the European Commission and agreed to apply the privacy standards of protection of the European Union;

  • If the Data Subject has provided consent to the transfer.

How Long Will We Store Your Personal Data?

We will cease to retain your Personal Data or remove the means by which the Personal Data can be associated with you after seven (7) years where your relationship with us has been terminated and/or as soon as it is reasonable to assume that such retention no longer serves the purposes for which the Personal Data was collected and is no longer necessary for legal or business purposes, except where retention is permitted or required by the Law and/or other applicable laws.

Protection of Personal Data

To safeguard your Personal Data from unauthorized access, collection, use, damage, loss, disclosure, copying or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data to Third Parties.

We also allow access to Personal Data only to those employees who need to know such data, and they will only process your Personal Data on our instructions.

However, no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we try to protect the security of the Data Subject’s Personal Data and constantly review and enhance our information security measures.

What Are Your Rights in Relation to Your Personal Data?

Right to Access

You may request access to your Personal Data, commonly known as a “data subject access request.” This enables you to receive a copy of the Personal Data that we hold about you at any time.

Right to Rectification

You may request that we correct or update any of your Personal Data which we hold. This enables you to have any incomplete or inaccurate information we hold about you corrected. We strive to retain only Personal Data that is accurate, complete and up to date.

Right to Data Portability

You may request the transfer of your Personal Data to another party.

Right to Erasure

You may request that we delete your Personal Data from our records. However, we may need to retain certain information for legal or administrative purposes, such as record keeping and detecting fraudulent activities.

Right to Restrict Processing

You may request that we restrict the use of your Personal Data.

Right to Object

You have the right to object to the collection and use of your Personal Data. For example, when we use your Personal Data on the basis of your consent, you can withdraw that consent at any time.

Right to Lodge a Complaint

You have the right to lodge a complaint about the use of your Personal Data by contacting the Office of the Commissioner for Personal Data Protection in Cyprus using the contact details below:

Office address: Iasonos 1, 1082 Nicosia, Cyprus

Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus

Tel: +357 22818456

Fax: +357 22304565

Email: commissionerdataprotection.gov.cy

Exercising Your Rights

If you wish to exercise any of your rights, you may contact our Data Protection Officer in writing or via email using the contact details provided below:

Address: 58 Raphael Santi, Nefeli Court 11, Ground Floor, 6052 Larnaca, Cyprus

Email: Data Protection Officer at dpo@toulouraslaw.com

The Data Protection Officer has the right to require the individual making the request to provide certain identification documents or information to verify their identity.

The Data Protection Officer will respond to your request within thirty (30) days after receiving your email or letter.

How Do We Protect Your Personal Data?

To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying or similar risks, we have introduced appropriate administrative, physical and technical measures.

You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we try to protect the security of Personal Data by constantly reviewing and enhancing our information security measures.

Effect of Policy and Changes to Policy

We keep the Potens Corporate Privacy Policy under review and may modify it from time to time without prior notice. You should review this Policy on our website periodically to ensure that you are aware of any modifications or updates.

Cookies Policy

Our website uses cookie technology. Cookies are small files saved to your computer or mobile device that track, save and store information, as well as your interactions with and use of our website.

The primary purpose for collecting data from users of our site is to allow us to provide a smooth, efficient and personalized experience while using our site.

Users are advised that if they wish to deny the use and saving of cookies from this website onto their computer’s hard drive, they should take the necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors.

We also collect other forms of non-personal information, such as browsers used to access our website, search terms used to find the website, traffic referrals and links to our website.

Cookies collected by us are used to enable certain functions and tools of our website, assist in the navigation of the website, track resources and data used on this site, and remember computer settings.

You may prevent your computer from accepting cookies by modifying the properties of your web browser. Please see your browser’s “Help” option for information on how to do this.

We also use the services of Google Analytics software to analyze traffic to our website. Neither of these programs creates individual profiles for visitors, nor do we collect any personally identifiable information using these services.

Data collected regarding site usage is compiled in aggregate to improve the performance of the website. If you do not wish your information to be included in this aggregated data through Google Analytics, modify the properties of your web browser to prevent your computer or mobile device from accepting cookies. Please read the Google Privacy Policy for further information.

Types of Cookies

Strictly Necessary Cookies

These cookies are necessary for the website to enable you to use certain features, such as requesting specific services, setting your privacy preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Functionality Cookies

These cookies are used to allow the website to remember choices you make, such as language preferences, and provide enhanced features to improve your web experience.

Navigation Cookies

These cookies enable the site to function correctly and are used to gather information about how visitors use the site.

This information is used to compile reports and help us improve the site. Cookies gather information anonymously, including the number of visitors to the site, where visitors came from and the pages they viewed.

Analytical Cookies

These cookies are used to produce statistical analyses of the way users navigate the site using computers or mobile devices, the number of pages viewed and the number of clicks made on a page during navigation of the site.

Disabling Cookies

You can prevent cookies from being set by adjusting the settings on your browser. Please see your browser’s “Help” option for information on how to do this.

Be aware that disabling cookies may affect the functionality of this and other websites that you visit.