Treppides Privacy Notice


Privacy Notice

Who We Are

K. Treppides & Co. Limited and its subsidiary Companies (‘we’ or ‘us’ or ‘our’ or ‘Group’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

K. Treppides & Co. Ltd was established in 1985. The company’s reputation has continued to expand as a leading practice providing a holistic range of audit, tax, accounting, legal, consulting and financial advisory services to international companies. Different clients’ success stories reflect the company’s innovative thinking in a range of industry sectors, including Banking and Investment Banking, Financial Services Firms, Manufacturing Companies, Internet Based Companies, Oil and Gas Companies and Shipping Companies. The Company values its relationship with its clients and takes an effort to maintain the privacy and the loyalty of each individual client by providing the requirement security.

The relevant Group entity with the primary relationship will be confirmed in an engagement letter in relation to any client relationship. Our offices include jurisdictions such as Cyprus, Malta and United Kingdom which have been deemed adequate for European Union Data Protection purposes.

Information That We Collect

In order for K. Treppides & Co. Limited to provide its clients with the best services, once an individual applies to become a client, he/she is being asked to provide a number of personal data.

K. Treppides & Co. Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and will not process your information in any way, other than as specified in this notice.

According to the General Data Protection Regulation (2016/679), personal data is defined as any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Any personal Data that will be collected by the Company through the provision of the Services, shall be processed according to the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).

The non-public personal data that we collect, and the processing of such information will vary on the basis of the purpose and scope of the particular use or engagement.

The type of data that we may collect and process are: -

  • Contact details (including names, postal addresses, email addresses and telephone numbers);
  • Information required for the Treppides Group to meet legal and regulatory requirements, in particular in respect of anti-money laundering legislation, including information on source of funds and source of wealth;
  • Information provided in the course of the provision of legal and governance services (for example, information on professional relationships and background, financial wealth and assets held, transactions entered into, tax status, disputes and court proceedings engaged in);
  • Financial information, such as payment related information;
  • Professional interests and events attended;
  • Meetings attended and visits to our offices;
  • Any other information you may provide to us.

We collect information in the below ways:

  1. In hard copy/ certified true copy format
  2. Through electronic communication means

How We Use Your Personal Data

We consider your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:

We process the Customer’s personal data:

  1. In order to provide the services agreed in the Service Agreement, and perform any other obligations in relation to the Service Agreement;
  2. In order for the Service Provider to comply with its Legal or Regulatory obligations; and
  3. Where it is for the purposes of our legitimate interests and those interests are not overridden by the data subjects’ own privacy rights.

We will occasionally send you marketing information (newsletters etc.) where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.

Your Rights

You have the right to access any personal information that K. Treppides & Co. Limited processes about you and to request information about: 

  • What personal data we hold about you;
  • The purposes of the processing;
  • The categories of personal data concerned;
  • The recipients to whom the personal data has/will be disclosed;
  • How long we intend to store your personal data for;
  • If we did not collect the data directly from you, information about the source.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

K. Treppides & Co. Limited uses third-parties to provide its services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

The following is a list of potential recipients of data (in each case including respective employees, directors and officers):

  • Other members of the Group;
  • Other providers of services (legal, administrative or otherwise, including any bank or financial institution providing services in relation to any matter on which the Treppides Group is instructed) where disclosure to that provider of services is considered necessary to fulfil the purposes set out above;
  • Any sub-contractors, agents or service providers of the Treppides Group;
  • Courts or tribunals;
  • Regulators or other governmental or supervisory bodies with a legal right to the material or a legitimate interest in any material;
  • Any registrar of a public register where the data is to be included in a public registry;

This may include only transferring the data where we are satisfied that we have obtained consent from relevant data subjects to the transfer.

In the event that any such third party is outside of the European Union and where the data being transferred would include personal data which would be protected under applicable Data Protection regulation we will ensure we meet the relevant requirements of that Data Protection regulation prior to carrying out any such transfer. This may include only transferring the data where we are satisfied that:

  • the non-European Union country has Data Protection laws similar to the laws in the European Union;
  • the recipient has agreed through contract to protect the information in the same Data Protection standards as the European Union;
  • we have obtained consent from relevant data subjects to the transfer; or
  • if transferred to the United States of America, the transfer will be to organizations that are part of the Privacy Shield.

Safeguarding Measures

We take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place.

Personal Data are processed in a manner that ensures appropriate security and confidentiality, including for preventing unauthorised access to or use of personal data.

The Company shall take all necessary measures in order to protect the security of all personal information. The Company shall protect all data from loss, misuse, unauthorised access or disclosure, alteration, or destruction.

The Company shall not be liable for unlawful or unauthorised use of any personal information due to misuse or misplacement of the passwords, negligent or malicious use.

The Company maintains policies and procedures and has measures in place in order to ensure high levels of protection of personal data which include, inter alia, appropriate restrictions on permissions of access to personal information, controls and monitoring of storing and distribution of data as well as Data Protection Impact Assessments. In addition, the Company maintains a Business Continuity Plan which safeguards the continuity of the business activity.

All employees and providers of the Company are required to follow certain privacy and security policies and procedures.

The Company is not responsible for the security and privacy of any Third Party and/or Social Networking services or any information collected by them. It is recommended that a User should always review the said providers privacy policies.

Legitimate Interests

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis..

Processing of personal data is performed in accordance with all applicable laws and regulations of the Republic of Cyprus and the European Union. The Company is obliged to process personal data fairly and lawfully, for a specified, explicit and legitimate purposes, and processed to the extent they are relevant, appropriate and not excessing in relation to the purposes of processing.


Purpose   Lawful Basis for Processing
To enter into client   Any one or more of the following:
relationships and provide professional services      
    The legitimate interest of the Treppides Group as a provider of
    professional services to process personal data for the
    purpose of providing those services as indicated in the Agreements with our clients.
    In instances where an individual has been provided with this
    Privacy Notice and provides personal data thereafter, the
    processing may be carried out on the basis of consent. Consent
    may be withdrawn at any time by writing to us.
     
To manage our client, intermediary and other business relationships   The legitimate interests of the Treppides Group to seek to ensure that its business is conducted efficiently and with a view to enhancing client service.
     
To ensure the security of Treppides systems, staff and premises (including the use of CCTV equipment)   The legitimate interests of Treppides Group in protecting its systems, staff and premises from being misused or the victim of any criminal activity.
       
To provide our contacts with marketing material and invite contact to events which may be of interest to the, and to manage such mailings and events  

The legitimate interests of the Treppides Group as a provider of professional services to process personal data to communicate with persons on topics and events which may be of interests communicate with persons on topics and events which may be of interest to those individuals.

       
    The right of those individuals to unsubscribe from mailings
   

and/or manage preferences will be noted within all mailings and any requests to unsubscribe may be made via links available in the mailings.

To meet all legal, regulatory and ethical obligations applicable to Treppides Group (including in respect of managing potential conflicts of interest) The legitimate interests of the Treppides Group as a provider of legal and governance services to process data to the extent necessary to ensure it meets all legal, regulatory and ethical obligations incumbent on it. In certain instances, the processing of data may also be necessary for the exercise of functions of public authorities and/or necessary for compliance with a legal obligation to which our Group is subject.
   
   
   
       
   
   
   
   

For the purposes of internal know-how and training

 

The legitimate interests of Treppides Group as a provider of legal and governance services to process data for the purposes of internal know-how and staff training. The Treppides Group will use reasonable endeavours to ensure any personal data contained in the material which is not integral to understanding of the material is redacted.
   
   
           


How Long We Keep Your Data

We retain the personal information that we collect from you only for as long as required for statutory, business, tax or legitimate interest purposes. Your information is retained in electronic or paper format or both. When it is no longer required, it will be deleted or destroyed. 

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Special Categories Data

Where we rely on your consent for processing special category data, we will obtain your explicit consent through a signature. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.

Changes to this Privacy Notice

This Privacy Policy will remain in effect except with respect to any changes in its provisions in the future. Any updates will appear on our website at www.treppides.com.

 Lodging A Complaint

K.Treppides & Co. Limited only possess your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

  


Contact Information

K. Treppides &Co. Limited

9, Kafkasou Street, Aglantzia

Treppides Tower

2112,Nicosia, Cyprus

Telephone: +357 22 678944

Fax : +357 22 681887

E-Mail: info@treppides.com

25 May 2018

Publications


OCTOBER iCAS Newsletter Issue 38/2018
The European Securities and Markets Authority ("ESMA") publishes its first Annual Statistical Report ("Report") on the European Union's ("EU") derivatives...
22 October 2018
OCTOBER iCAS Newsletter Issue 37/2018
The Governing Council agreed to maintain the current monetary policy stance at its September monetary policy meeting. 
15 October 2018
OCTOBER iCAS Newsletter Issue 36/2018
The aim of the European Central Bank ("ECB") Macroprudential Bulletin is to raise awareness of macroprudential policy issues in the euro...
08 October 2018
SEPTEMBER iCAS Newsletter Issue 35/2018
The Financial Conduct Authority ("FCA") has published a Decision Notice Concerning Linear Investments Limited.
02 October 2018
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