We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data, we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant CYPRUS and EU legislation and our professional duty of confidentiality.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	A. NICOLAOU & ASSOCIATES L.L.C.
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership

Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal data we will collect	Personal data we may collect depending on what you have instructed us
Your name, address and telephone number   Information to enable us to check and verify your identity, e.g., your date of birth or passport details Electronic contact details, e.g., your email address and mobile phone number Information relating to the matter in which you are seeking our advice or representation Information to enable us to undertake a credit or other financial checks on you Your financial details so far as relevant to your instructions, e.g., the source of your funds if you are instructing us on a purchase transaction and/or if you are instructing us on fiduciary services.	Your National Insurance and tax details Your bank and/or building society details Details of your spouse/partner and dependants or other family members, e.g., if you instruct us on a family matter or a will and etc Your employment status and details including salary and benefits, e.g., if you instruct us on matter related to your employment or in which your employment status or income is relevant and etc. Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship and etc Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), e.g. if you instruct us on matter related to your employment or in which to sickness and attendance, performance, disciplinary, conduct and your employment records are relevant and etc if you instruct us on matter related to your employment or in which Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g., if you instruct us on discrimination claim Your trade union membership, e.g., if you instruct us on discrimination claim or your matter is funded by a trade union and etc.
	Personal identifying information, such as your hair or eye colour or your parents’ names, e.g., if you instruct us to incorporate a company for you and etc. Your medical records, e.g., if we are acting for you in a personal injury claim or for court of protection purposes and etc.

This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information directly from you, however, we may also collect information:

• from publicly accessible sources,
• directly from a third party, e.g.:
• sanctions screening providers;
• credit reference agencies;
• client due diligence providers;
• from a third party with your consent, e.g.:
• your bank or building society, another financial institution or advisor;
• consultants and other professionals we may engage in relation to your matter;
• your employer and/or trade union, professional body or pension administrators;
• your doctors, medical and occupational health professionals;
• via our website—we use cookies on our website (for more information on cookies, please see our cookies policy)
• via our information technology (IT) systems, e.g.:
• case management, document management and time recording systems;
• automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data for	Our reasons
To provide legal services to you Conducting checks to identify our clients and verify their identity	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations
Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information Statistical analysis to help us manage our practice, e.g. in relation to our client base, work type or other efficiency measures	For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating client records	For the performance of our contract with you or to take steps at your request before entering a contract. To comply with our legal and regulatory Obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory Obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: —existing and former clients; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients

The above table does not apply to special category personal data, which we will only process with your explicit consent.

Promotional communications
We may use your personal data to send you updates (by email, text message, telephone, or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• contacting us by emailing agathi.nicolaou@nicolaoulawfirm.com
• using the ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal data with

We routinely share personal data with:

• professional advisers who we instruct on your behalf or refer you to, e.g. barristers, medical professionals, accountants, tax advisors or other experts;
• other third parties where necessary to carry out your instructions, e.g. your mortgage provider or Land Registry in the case of a property transaction or Companies House;
• courts and Tax Revenue;
• credit reference agencies;
• our insurers and brokers;
• our IT providers;
• external auditors;
• our bank;

We only allow our service providers to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal data is held
Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept.

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

When it is no longer necessary to retain your personal data, we will delete it.

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g.:

• with your and our service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the matter in which we are advising you. These transfers are subject to special rules under European and Cyprus data protection law.

These non-EEA countries do not have the same data protection laws as the Cyprus and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure.

If you would like further information, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
To be forgotten	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

If you would like to exercise any of those rights, please:

• email, call or write to us. See below: ‘How to contact us’; and
• let us have enough information to identify you (e.g. your full name, address and client or matter reference number);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Cyprus and the information is stated below:

Cyprus Data Protection Commissioner
Cyprus Regulatory Authority
Τ.Θ. 23378, 1682 Nicosia
Email: commissioner dataprotection.gov.cy
Phone: (+00357) 22818456
Fax: (+00357) 22304565

Changes to this privacy policy
This privacy policy was published on 2023.
We may change this privacy policy from time to time.

How to contact us
Please contact us and/or by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you.

Our contact details are shown below:

Our contact details	Privacy Officer’s contact details
A. Nicolaou & Associates L.L.C. Ιωάννη Χάκκετ 44, Merika House 3, 3rd floor, off. 6, 6045 Larnaca Cyprus	Voulla Stavrou 00357 24642156 voulla.stavrou@nicolaoulawfirm.com