1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
Multi-consult Limited (“we”, “us”, “our” and “ours”) offers fiduciary and administration services. We are registered in Cyprus as a limited liability company under number: 22322 and our registered office is at Agiou Prokopiou 13, 2406 Egkomi, Nicosia Cyprus.
For the purpose of the General Data Protection Regulation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the GDPR to notify you of the information contained in this privacy notice.
Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example,:
- when you request a proposal from us in respect of the services we provide;
- when you, your employer, organisations with whom you have dealings (including but not limited to banks and other professional service providers), or our clients engage us to provide our services;
- when you contact us by email, telephone, post or social media (for example when you have a query about our services); or
- when you submit an application for employment through our website or email or other communication;
- from third parties and/or publicly available resources (for example, from representatives of our clients, your employer or from the Registrar of Companies).
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal details (such as your name, address, telephone, email etc);
- information we are legally required to collect for compliance purposes, such as ‘know your client’ information (such as your ID number and/or passport number, CV, reference letters)
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of bank accounts;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- details provided as part of an application for employment;
- information from research, surveys, and marketing activities obtained in compliance with the GDPR;
- Information we receive from other sources, such as publicly available information, information provided by your employer, organisations with whom you have dealings, our clients or information from our member network firms.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for the purposes of responding to requests for services and/or other enquiries including in relation to performance of our contract with you (for example, in relation to accounting, consultancy and/or administration services we may provide) , your employer, organisations with whom you have dealings or to comply with our legal obligations.
We may process your personal data for the purpose of performing our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purpose of compliance with regulations, professional rules and laws applicable to us (such as Anti Money Laundering Laws and Tax Laws) that we are subject to.
We may also process your personal data to comply with court orders, orders from any regulatory body to which we are subject and/or to defend our legal rights.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes always in accordance with the GDPR.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into (between you, your employer, organisations with whom you have dealings and us) which will most usually be for the provision of our services;
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services where you may be a subcontractor, supplier or customer of our client);
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- seek your feedback on the services we provide; and
- notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory, regulatory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might you share my personal data with third parties?
We may share your personal data with third parties where we are required to do so by law, where it is necessary to administer the relationship between us (such as collaborators including lawyers, banks and other professional service providers), where we have your express consent or where we have another legitimate interest in doing so.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator, to otherwise comply with the law or in connection with any legal proceedings.
Personal data about other individuals which you provide to us
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
Where we collect your personal information within the EEA, transfer outside the EEA will be only:
- to a recipient located in a country which provides an adequate level of protection for your personal information; and/or
- under an agreement which satisfies EU requirements for the transfer of personal data to data processors or data controllers outside the EEA, such as standard contractual clauses approved by the European Commission.
- undertaken in accordance with any other applicable data protection laws.
8. DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality as well as other obligations regarding the security of the personal data they process.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email us at email@example.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in accordance with the law.
12. CHANGES TO THIS NOTICE
We may amend or update this privacy notice from time to time. All amendments or updates will be posted on our website and/or in our standard terms of business and/or in any other appropriate communication or document exchanged between us.
This privacy notice was last updated on 15 May 2018.
13. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data or to raise a complaint, please email us at firstname.lastname@example.org or telephone on 22556500.
You also have the right to make a complaint to the Office of the Commissioner for Personal Data Protection, the Cyprus supervisory authority for data protection issues, at any time. More information can be found at www.dataprotection.gov.cy.