Disclaimer

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PATRIKIOS PAVLOU & ASSOCIATES LLC (the “Firm”) are committed to protecting and respecting your privacy.

This policy and any other documents referred to on it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will use it and treat it. By providing us with your personal information and using our services, you are accepting and consenting to the practices described in this policy.

For the purposes of EU Regulation 2016/679 (the EU General Data Protection Regulation) hereinafter referred to in this policy as the “GDPR”, the Data Controller is PATRIKIOS PAVLOU & ASSOCIATES LLC of Patrician Chambers, 332 Agiou Andreou Str., 3035 Limassol, Cyprus.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

• Information you give us. This is information about you that you give us by filling our client forms, engagement letters, retainers or by corresponding with us by phone, e-mail, in person or otherwise. It includes information you provide when you choose to use our services and/or become an affiliate to our firm, participate in any firm event and when you send any information to us under any capacity. The information you give us may include your name, address, e-mail address and phone number, financial information, personal description and photograph. When you visit our website (and/or websites) we collect information about your visit, including the full Uniform Resource Locators (URL),

• Information we receive from other sources. This is information we receive about you if you use any of the websites we operate or the services we provide and/or from other affiliates and/or professionals. In this case, we will have informed you when we collected that data and if we intend to share those data internally. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

• to provide you with information about other services we offer that are similar to those that you have already used or enquired about;

• to notify you about changes to our service;

Information we collect about you. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

• as part of our efforts to keep our site safe and secure;

Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR INFORMATION

You agree that we have the right to share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined under the Cyprus Companies’ Law.
• Selected third parties including:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• business publications and/or legal and/or business directories. We will always ask for your consent to release material information relating to your personal data and/or particulars of a case handled by us and/or any services provided by us.
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• credit reference agencies and/or banking/financial institutions for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
• Compliance software for the purposes of complying with local and international regulations against money-laundering, fraud and the general prevention of crime and illegal activities and/or the cooperation with the authorities and/or the police

We will disclose your personal information to third parties:

• In the event that this is necessary for the provision of services provided to you.
• If PATRIKIOS PAVLOU & ASSOCIATES LLC or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal and/or regulatory obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of PATRIKIOS PAVLOU & ASSOCIATES LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, anti-money laundering and credit risk reduction.

COLLECTION OF DATA UNDER MONEY-LAUNDERING POLICIES AND PROCEDURES

The Firm conducts client due diligence enquiries on each new client and persons connected with them and conducts ongoing monitoring of existing clients. These enquiries are based on the FATF Recommendations, and the EU Third Money Laundering Directive, although if additional information is required, that information will also be obtained. Where necessary for these purposes, we may seek relevant information from third party data suppliers. Where individuals have supplied personal data for this purpose we will only use it for that purpose and will keep it only as long as the relevant AML and data protection legislation requires.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you will be stored locally at our servers. However, certain email communications and/or data transmitted to us over email and/or other means of electronic transfer of documents may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and the GDPR.

All information you provide to us is stored on our secure servers. Where we may have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

COOKIES

Our website uses cookies. By using the Firm website and/or any other affiliated website, you are agreeing to our use of these cookies. Cookies allow us to distinguish you from other users of our website. The information that we collect in this process will not identify you as an individual. This helps us to provide you with the best experience and also allows certain parts of our site to function correctly.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by letting us know when we collect your data. You can also exercise the right at any time by contacting us at: Patrician Chambers, 332 Agiou Andreou Str., 3035 Limassol, Cyprus or at info@pavlaw.com

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

REVISIONS TO THIS POLICY

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes.

ACCESS TO INFORMATION

You have the right to be provided and/or access and/or amend and/or rectify information held about you. Under certain conditions, your right of access can be exercised in accordance with the law. Any access request will be subject to a fee of €10 to meet our costs in providing you with details of the information we hold about you, although we have the discretion to waive this.

We aim to comply with requests for access to personal information as quickly as possible and will ensure that we comply with legislation unless exceptions apply. In such cases, the reason for any delay will be explained in writing to the data subject making the request.

In processing a request, the identity of the data subject has to be verified before information will be released. No personal data will be disclosed to a third party without the written consent of the data subject. We reserve the right to refuse repeated/vexatious requests

CONTACT INFORMATION

If you have any questions in relation to this policy please contact us at: info@pavlaw.com. You may send all Data Protection and Privacy related Inquiries to our address, marked “Confidential – For the attention of the PATRIKIOS PAVLOU & ASSOCIATES LLC – Data Protection Officer”.