BYBLOSERVE MANAGEMENT LIMITED (“we”, “us” or “our” in this privacy notice) respects your privacy and the protection of the security and confidentiality of your personal data is of outmost importance to us. This privacy notice will inform you as to how we use and look after your personal data and tell you about your privacy rights and how the law protects you when:
- you visit our website; and/or
- you sign up to receive information about us, our services and events; and/or
- you are a client or prospective client of us; and/or
- you are a contact of us; and/or
- you are connected to a client or prospective client of ours or a matter in respect of which we receive instructions from a client of ours
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and process your personal data in the circumstances listed in (i) to (v) above.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.
DATA CONTROLLER
The data controller is BYBLOSERVE MANAGEMENT LIMITED, a duly registered limited liability company in Cyprus under registration number 252361 with its registered office at 57 Spyrou Kyprianou Avenue,Bybloserve Business Center, Larnaca 6051, Cyprus
DATA PROTECTION OFFICER (DPO)
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO using the details set out below.
Contact details:
DPO name: Georgia Thoma
Address: 10 Patron street, 6051 Larnaca
Email address:
dpo@bybloserve.com
Tel: 24812581
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Any changes to this privacy notice will be posted on our website (www.bybloserve.com) and where appropriate notified to you in writing.
THIRD-PARTY LINKS
Our website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data is any information about a person from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes personal data stated in your birth certificate such as name, titles, other similar identifiers, marital status, date of birth, gender, as well as other identity data such as passport number, identity number or Tax Identification number).
- Contact Data includes residential, correspondence and email addresses and telephone numbers.
- Financial Data includes bank account details and other data necessary for processing payments and fraud prevention and other details about payments to and from you.
- Matter Data includes communications and documents created in respect of any matter in which we act for you or another client of ours.
- Marketing and Communications Data includes your preferences in relation to receiving information about us, our services and events.
- Technical data, including information collected during your visits to our website. For more information about our use of cookies, please read our Cookie Notice on our website .
- Data collected from the security systems: records from the cameras through the Closed-circuit television (CCTV).
- Special categories of personal data may be collected and used in the course of providing our services to you. Such data includes information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life and sexual orientation or details of criminal offences or genetic or biometric data.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
4. WHY DO WE COLLECT AND PROCESS YOUR PERSONAL DATA?
We use your personal data only for the following purposes:
- when it is necessary for the performance of a contract or in order to take steps prior to entering into a contract. This includes:
- to register you as a client;
- to provide our services as instructed by you or your organisation;
- to be provided with services by you or your organisation;
- to process payments, billing and collection.
- when it is necessary for the purposes of the legitimate interests of our business, particularly:
- to administer and manage our relationship with you, including accounting, auditing, and taking other steps linked to the performance of our business relationship including identifying persons authorised to represent our clients, suppliers or service providers;
- to carry out background checks, where permitted;
- to analyse and improve our services and communications and to monitor compliance with our policies and standards;
- to manage access to our premises and for security purposes;
- to protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
- for insurance purposes;
- to exercise or defend our legal rights or to comply with court orders;
- to provide legal advice and legal services to our clients; and
- to communicate with you to keep you up-to-date on the latest developments, announcements, and other information about our services and solutions (including briefings, newsletters and other information), events and initiatives; marketing campaigns or other promotional activities; and
- to collect information about your preferences to personalise and improve the quality of our communications with you.
Closed-circuit television (CCTV) is also used for purposes of our legitimate interests,
especially for:
- the crime prevention and detection
- the security and protection of our premises
- the security of Clients and Employees
- assuring the Clients and Employees of their security thanks to the measures that have been taken and thus reducing the fear of crime
- assisting the local law enforcement authorities with the crime detection and prevention, including the fight against terrorism.
- when it is necessary for the protection of the vital interests of employees or any other physical persons. This includes, inter alia,
- managing incidents, sicknesses, accidents, injuries or cases of emergency at our premises
- contacting you or any other relevant contact person in case of emergency
- when it is necessary for compliance with a legal obligation, including maintaining records, compliance checks or screening and recording (e.g. for tax purposes, for fraud and crime prevention and detection etc.). This can include sharing your personal data with third parties, such as the competent law enforcement authorities
- when it is necessary for performing a task in the public interest and this task has a clear basis in law
- when processing is necessary for compliance with a legal obligation, including maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions, etc). This can include automated checks of personal data you provide about your identity against relevant databases and contacting you to confirm your identity, or making records of our communications with you for compliance purposes.
- When you give us your consent to process your personal data:
- to communicate with you to keep you up-to-date on the latest developments, announcements, and other information about our services (including briefings, newsletters and other information), events and initiatives; to send you details of client surveys, marketing campaigns, or other promotional activities.
- to collect information about your preferences to personalise and improve the quality of our communications with you.
We will not use your personal data for taking any automated decisions affecting or creating profiles.
OPTING OUT
You can ask us to stop sending you information about us, our services or events at any time by
contacting us at dpo@bybloserve.com.
Where you opt out of receiving information about us, our services or events, your opt out will not apply to personal data provided to us for any other purpose.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about our use of cookies, please read our Cookie notice on our
website.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data in the following circumstances:
- with any member of our group of companies, including any of our subsidiaries and/or affiliate companies, for the purposes for providing our services as described herein.
- with third parties including other lawyers, advisers and expert witnesses and other legal specialists, translators, couriers and other necessary entities and/or subcontractors, for the purposes for providing our services as described herein;
- to our client, if your personal data has been collected in the course of providing our services to our client;
- with service providers (including providers of IT services);
- with regulatory bodies, law enforcement agencies, or pursuant to an order of a court or a legal obligation, to enforce our terms of business or to protect the rights of our business, our employees and our clients and
- with any other third parties for example in the context of a merger, sale or restructuring of our business.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. TRANSFER OF PERSONAL DATA OUTSIDE EUROPEAN ECONOMIC AREA (EEA)
We do not transfer any personal data to countries outside the EEA.
Nonetheless, it might be necessary to do so for the purposes of providing our services and we will take steps to ensure that your personal data receives an adequate level of protection. In case where your personal data is transferred to a service provider for processing in any country outside the EEA that is not recognized by the EU Commission as providing an adequate level of protection for personal data, we will ensure that appropriate safeguards as per the EU Commission’s standard contractual clauses or by any other appropriate safeguard as foreseen under the applicable data protection law are provided.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
- Site Access Control: unauthorised persons are not allowed to gain access to areas within our firm whereby personal data are processed and in case where the provision of access to such persons is necessary, they do not remain unattended.
- System Access Control: only authorised persons have access to data processing systems.
- Data Access Control: authorised persons with access to data processing system have access only to the data they are authorised to access and are bound by confidentiality.
- Transfer Control: personal data are only transferred in prescribed manner and under certain circumstances.
- Disclosure Control: we always ascertain and check where and to whom data can be transferred by means of data transmission facilities.
- Order Control: personal data of a data subject is processed in strict accordance with the data subject’s instructions and the appropriate law.
- Breach Control: procedures to deal with any suspected personal data breach and for the notification of any applicable regulator or an affected data subject of a breach have been laid down.
Our security measures are audited regularly by external security experts in order to maintain our security level to international standards and to ensure that personal data is handled in a secure way.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for and in case where a client relationship existed we will retain your personal data for a period of at least five (5) years thereafter.
As for the CCTV records, they are retained for a period of one (1) month from the recording date. However, we may have to retain this data for a longer period, such as for defending our legal rights before courts or other enforcement authorities.
In general, to determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We may keep such data for longer periods for our legitimate business interests, or to comply with legal or regulatory obligations or to protect your or others’ vital interests.
In some circumstances you can ask us to delete your data: see below for further information.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights in relation to your personal data:
Right of Access: You have the right to access to your personal data. You can ask for a copy of the personal data we hold about you. There are situations where we may deny your request, for example, if making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information.
Right to Rectification: It is our objective to keep your personal data accurate, current and complete. You have the right to request the correction of any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
Right to Erasure: You have the right to ask us to delete your personal data where there is no reason to continue processing it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to the processing, where we may have processed your data unlawfully or where we need to delete your personal data to comply with the law. Note, however, that we may not always be able to comply with your request for deletion for specific legal reasons for which we will notify you, as appropriate, at the time of your request.
Right to Object: You have the right to object to the processing of your personal data when 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 ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds which override your rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes.
Right to Restrict Processing: You have the right to ask us to suspend the processing of your personal data in the following cases: (a) if you want us to establish the data’s accuracy, (b) when our use of the data is unlawful but you do not want us to erase it (c) when you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or (d) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to Data Portability: You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Right to Withdraw Your Consent: You have the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before the withdrawal of consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the abovementioned rights, please contact us at
dpo@bybloserve.com.
If you wish to exercise any of the rights set out above, please contact us at
dpo@bybloserve.com.
RIGHT TO FILE A COMPLAINT
You also have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection. Please find more information at the official website of the Commissioner at
www.dataprotection.gov.cy.
NO FEE USUALLY REQUIRED
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Updated 15.04.2020