Πολιτική Απορρήτου

1. Purpose

In accordance with the General Data Protection Regulation (GDPR) this privacy notice describes how we collect and use personal data about you (data subjects).

This notice is made available to the attention of data subjects prior to processing their personal data and if required under GDPR their consent to the processing of their data is secured.

2. About us

Fidesta Ltd (the ‘Company’, “we”, “us”, “our”) is a limited liability company incorporated in Cyprus, with registration number HE351992. The company offers a wide spectrum of company administration services and since 2019 is regulated under the Cyprus Securities and Exchange Commission for the management or directing of trusts and the undertaking or provision of the service of managing companies under license number 197/196. The registered office of the Company is at 77 Strovolou, Strovolos Business Centre, Office 401, 2018 Strovolos, Nicosia, Cyprus.

Our Data Protection Officer and data protection representatives can be contacted directly here

• (+357) 22818018
• 77 Strovolou, Strovolos Business Center, Office 401, 2018 Strovolos, Nicosia, Cyprus

3. Personal Data we may collect from you
   

The personal data we would like to collect from/process on you is:

Contact information: Information such as your name, job title, postal address, home address, business address, telephone number, mobile number, fax number and email address.

Business details: Business information which we necessarily process as part of our instructions or assignments we are involved in or otherwise provided by you voluntarily.

Correspondence: Details of any correspondence with you, including but not limited to details of contact we have had with you in relation to the provision, or the proposed provision, of our services, details of any services you have received from us, and our correspondence and communication with you.

Compliance details: Information we are legally required to collect for compliance purposes, such as ‘know your client’ information, details relevant to international sanctions and restrictive measures and information about relevant and significant litigation, which may impact our ability to act.

Publicly available information: Information collected from publicly available resources, including but not limited to information collected from databases we use to carry out compliance checks or credit rating agencies.

Statutory information: Information about you on account of an interest or office you may hold in or certain relationships you may have with a corporate entity, partnership, trust or other vehicle to which we provide services (each such entity, a Third Party Entity).

4. How we collect your personal Data

Your personal data may be collected by Fidesta Ltd in the following cases:

• When requesting our services and an engagement letter/terms of business is signed
• When you submit an online enquiry through our website or through email/telephone
• When a Third Party Entity engages us to provide services that you hold an interest in

Your personal data may be collected directly from you or from third parties including third party entities, government agencies or from publicly available records.

5. How we use your personal data

The personal data we collect will be used for the following purposes:

• Provision of our services as per the client engagement letter/Terms of Business as instructed or requested by you
• Know your client process for prevention of money laundering
• Anti-money laundering compliance requirements
• To analyze and improve our services and communications to you
• On instruction or request from your organization or a relevant Third Party Entity
• We will only use your personal information for direct marketing purposes if:
• (a) you have given us your explicit consent to do so (opt in), in which case you may revoke such consent at any time, or
• (b) where we believe that such processing is necessary for pursuing our legitimate interests, in which case you have the right to object to such processing (opt out).
• For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us

Our legal basis for processing for the personal data:

The personal information collected is used by Fidesta Ltd to comply with legal and compliance requirements as part of our engagement and acceptance of any client for the provision of our services.

You can request to view, amend the details, object to processing or withdraw any consent we may hold on processing information about you.

It may further be the case that personal information we hold about you is shared with third party service providers as part of our obligations to fulfil the terms of engagement of our services.

6. Transfer of personal data outside the European Economic Area (EEA)

Fidesta Ltd may have to pass on your personal data to third parties which are non EU/International organizations. By signing this policy notice you provide us with your consent to pass on your personal data for the following purpose(s) as part of the processing activities and also in order to be able to fulfill our contractual obligations towards you. You also acknowledge you are informed of the possible risks of such transfers for you due to the absence of an adequacy decision and appropriate safeguards.

In the case that your personal information is transferred outside the EEA, Fidesta will take appropriate steps that your consent is received where needed and to ensure its security and confidentiality in accordance with applicable data protection law.

The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.

7. Data Retention

 Fidesta Ltd will process and store personal data for the period as required by the law and for as long as it is necessary to fulfill the purposes for which it is collected.

8. Change of purpose

In the case that your personal data is needed for a new purpose other than for the purpose that was initially obtained or where the new purpose is not compatible with the original purpose then you will be notified of the legal basis and obtain your consent before starting any new processing.

9. Rights of access, correction, erasure and restriction

 At any point your personal data changes then we need to be made aware by contacting us using the contact details provided in this privacy notice.

Under certain circumstances you have following rights:

• Right of access to the personal data we hold about you.
• Right of correction we hold about you that is inaccurate or incomplete.
• Right to request erasure, delete or remove your personal data from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right to object to processing your personal data
• Right of portability of your personal data to have the data we hold about you transferred to another organisation.
• Right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling.
• Right to request restriction of processing of your personal data if you want us to establish its accuracy or the reason for processing it.
• Right to judicial review in the event that Fidesta Ltd refuses your request under rights of access, we will provide you with a reason as to why.

By signing this policy notice you provide us with your explicit consent (opt in) to process your personal data for direct marketing reasons. You have the right to revoke such consent at any time by filling in and submitting to us the Data Subject Consent Withdrawal form, which we can provide you with upon request.

10. Right to withdraw consent

You have the right to withdraw your consent at any time by contacting us. We will no longer process your personal data for the purpose or purposes unless we have another legitimate basis for doing so in law.

11. Data sharing

We may share your personal data with third party service providers, where we are required by law, when it is necessary to fulfil our services as per our engagement letter or when there is any other legitimate reason in doing so. We will pass your personal data to a third party only once we have obtained your consent, unless we are legally required to do otherwise.

Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf.

12. Cookies

Cookies are text files that are stored on your device whenever you visit our website. These could be used for security reasons or for statistical analysis such as the number of users and frequency.

Your web browser may be configured by default to accept cookies. Such browser settings may be changed to receive alerts or prevent the cookies altogether.  

13. Changes to this notice

Any changes to our privacy notice will be updated on our website or you will be informed by email.

This privacy notice was last updated on 22/11/2023 .

14. Contact us

If you have any questions about your personal data you can contact our Data Protection Representative as per the details provided below.

If you have a complaint about how your personal data is processed or how your complaint was handled directly to the supervisory authority and our data protection representative.

The details for each of these contacts are: