MARICORP CYPRUS CONSULTANCY Privacy Notice for the Protection of Personal Data
October 2023
- Introduction
This notice (“Privacy Notice”) provides an overview of how MARICORP CYPRUS CONSULTANCY LIMITED (“MARICORP”) is Processing Personal Data of natural persons. This Privacy Notice is directed to and applies to you in cases where you are connected to an entity as a director, secretary, shareholder and/or Ultimate Beneficial Owner.
For the purposes of this Privacy Notice “Processing” refers to 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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
For the purposes of this Privacy Notice, “Personal data” shall mean 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, in particular 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.
ln all cases, MARICORP is committed to process your Personal Data in compliance with the provisions of applicable Personal Data protection law (including the GDPR, applicable as of 25 May 2018). The rights provided to you by the GDPR in relation to the Processing of your Personal Data by MARICORP are also described in this Privacy Notice.
- Who is responsible to process your Personal Data
Your Personal Data will be held by MARICORP, which will be responsible for its processing. If you wish to contact the Company in relation to the processing of your personal data, you may do so using the following contact details:
Maricorp Cyprus Consultancy Ltd HQ: 81 Griva Digeni Avenue, 6043, Marinos Court, Office 301, Larnaca Limassol: 89 Griva Digeni Avenue, 3101, Nicolaou & Zavos Center, Office 205 |
Alternatively, you may contact the Head of Compliance at:
P +357 24 663570
E compliance@maricorp.com.cy
- What Personal Data is Processed
The Personal Data Processed may be any or all the following types:
- Identification data including national identification numbers
- Contact details such as telephone number, home address, work address and email address.
- Financial such as information on your personal wealth including your assets etc.
- Socio-Demographic. This includes details about your work or profession, nationality, education.
- Transactional data
- Why we Process your Personal Data and on what legal basis
- Legal Basis – The law allows MARICORP to process Personal Data, only if the Company has a proper reason to do so. MARICORP processes your Personal Data to provide you with the requested services.
- When it is a legal obligation – MARICORP processes your Personal Data to comply with requirements of the legal and regulatory framework governing its operations including but not limited to anti-money laundering legislation, tax legislation and regulations, directives/ guidelines issued by Cyprus Bar Association, CySEC and other authorities such as Tax Authorities.
- When it is in the legitimate interests of MARICORP or another person with whom the data are shared – MARICORP may process your Personal Data in case it has a legitimate interest to do so, provided this interest does not unfairly go against what is right and best for you.
- When you consent to the use – MARICORP may base the Processing on your consent if such consent is free, specific, and has been given after you have been clearly informed about the details of the Processing. You have the right to withdraw your consent at any time, but such withdrawal does not affect the legality of the Personal Data processed prior to the withdrawal. When it is in the public interest or in the exercise of official authority vested in MARICORP – MARICORP may process your Personal Data when it is necessary for the public interest by virtue of official authority granted to MARICORP and provided that the Processing is performed lawfully and fairly, in a clear, precise, and transparent manner.
- For how long your Personal Data is retained by MARICORP
- Existing relationships – MARICORP processes and stores your Personal Data as long as you are a client of MARICORP and/or you maintain any type of relationship with MARICORP, and such Processing is necessary for the performance of the Company’s business and other legal obligations.
- Terminated relationships – After you stop being a client of the Company or you stop maintaining any type of relationship with the Company, MARICORP may keep your Personal Data for a period of up to 10 (ten) years from the date of termination for the following reasons:
• To maintain records according to rules that apply to MARICORP such as under applicable tax, money laundering laws and regulations.
• To respond to any questions or complaints.
• To demonstrate if needed that MARICORP treated you fairly.
• To preserve evidence that may be needed for the establishment, exercise, or defense of legal claims.
It is clarified that if MARICORP holds your Personal Data because you are related to a client of MARICORP (e.g., you are a representative, beneficial owner, officer, or guarantor), MARICORP may keep your Personal Data for any of the above reasons for up to 10 years after the end of the relationship of the Company with the relevant client.
We may keep your Personal Data for longer than the said period:
• If we cannot delete it for legal and/or regulatory and/or technical reasons. If we do so, we will ensure that your privacy is protected, and the Personal Data is used only for the purposes stated in paragraph 4 above.
• For research or statistical purposes. If we do so, MARICORP will make sure that your privacy is protected, and your Personal Data is processed only for research or statistical purposes.
(c) Prospect Clients – In case you provide us with Personal Data for the purposes of becoming a client of MARICORP but for any reason whatsoever you do not become a client, we shall keep your personal information for a period of up to 6 (six) months from the date of rejection or termination of the business relationship, in accordance with directives/guidelines issued by the Cyprus Commissioner for the Protection of Personal Data.
(d) Other provisions – In all respects, where a shorter or longer time period for the retention of Personal Data is provided for by law or regulatory acts, the retention period mentioned above will be reduced or increased accordingly.
8. Consequences for refusal to provide your Personal Data
Kindly note that if you do not provide us with the Personal Data which is legitimately required, then we will not be allowed / or be able to commence or continue our business relationship with you or another relevant person.
9. Your Rights
a. Right to access Personal Data
You have the right to obtain from MARICORP confirmation as to whether or not your Personal Data is being processed and/or obtain access to your Personal Data held by the Company.
- Right to rectification of Personal Data
You have the right to question any Personal Data MARICORP holds about you that you think is wrong or incomplete. If you do, MARICORP will take reasonable steps to check its accuracy and correct it
- Right to erasure (“right to be forgotten”)
You have the right to have MARICORP delete or remove your Personal Data in the following circumstances:
• The Processing of Personal Data by MARICORP is no longer necessary for any of the reasons the Personal Data was collected and used.
• You have withdrawn your consent and there is no other reason for the Personal Data Processing.
• You have successfully objected to the Processing of the Personal Data by MARICORP.
• The Personal Data has been unlawfully processed.
• Deletion is required by law.
It is clarified that MARICORP reserves its right to deny the said erasure, if the Processing is necessary for the Company to comply with its legal obligation, for reasons of public interest and/or for the exercise of its legal claims.
- Right to restriction of Processing of your Personal Data
You also have the right to restrict MARICORP’s use of your Personal Data in the following circumstances:
• pending verification by MARICORP of Personal Data the accuracy of which you have contested
• the Processing is unlawful, but you do not want your Personal Data to be erased
• MARICORP no longer needed the Personal Data, but you do not want it to be erased because you need it for the establishment, exercise, or defense of legal claims
• pending MARICORP’s assessment where you have objected to Processing intended to safeguard MARICORP’s legitimate interests.
- Right to data portability
You have the right to receive your Personal Data from the Company in a structured, commonly used, and machine-readable form.
You can also ask MARICORP to transfer your Personal Data in this format to other organizations, where this is technically feasible. This right relates to the Personal Data which you have provided to MARICORP and which MARICORP processes electronically in reliance on your consent or for fulfilling the business arrangement between you and MARICORP.
- Right to object
You have the right to object to MARICORP’s use of your Personal Data and ask MARICORP to stop using your Personal Data in any of the following circumstances:
• You have the right to object, on grounds relating to your particular situation, at any time to Processing of your Personal Data which is intended by MARICORP to safeguard its legitimate interests or to serve the public interest. If you lodge an objection, MARICORP will no longer process your Personal Data unless the Company can demonstrate compelling legitimate grounds for the Processing which override your interests, rights, and freedoms or unless the Processing is for the establishment, exercise, or defense of legal claims.
• You have the right to object to the Processing of your Personal Data for direct marketing purposes, including profiling. If you lodge such an objection, your Personal Data will no longer be processed for such purposes.
• You have the right to object to the Processing of your Personal Data for scientific or historical research purposes or statistical purposes, on grounds relating to your particular situation, unless the Processing is necessary for the performance of a task carried out for reasons of public interest.
- Right to withdraw your consent
Where MARICORP relies on your consent for the Processing of your Personal Data, you can withdraw your consent at any time. If you withdraw your consent, MARICORP may not be able to provide certain products or services to you. If this is so, MARICORP will tell you before giving effect to your withdrawal notification.
Please note that the withdrawal of the consent does not affect the legality of the Personal Data processed prior to the withdrawal.
10. Filing a complaint
If you are unhappy with how MARICORP processes your Personal Data, please inform the Company in any of the following ways:
• by calling MARICORP’s contact details (+357 24663570);
• by sending an email to Compliance department (compliance@maricorp.com.cy); or
You also have the right to complain to the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus. You can find information regarding the filing of complaints on the relevant website (http://www.dataprotection.gov.cy).