PG Premium Dynamic Services 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.
- 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.
The data controller processing your personal data is PG Premium Dynamic Services Limited , a duly registered limited liability company in 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.
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.premium-dynamic.com) and where appropriate notified to you in writing.
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 or in work reference letter such as name, titles, other similar identifiers, marital status, employment history, educational background, job title and function, date of birth, gender, as well as other identity data such as passport number or TIC’s (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 collated or 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.
- 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:
- Direct interactions with you. You may give us your data electronically, by phone, by post, during a meeting or otherwise. This includes personal data you provide when you:
- Contact us via our website;
- Provide us Identity, Contact, Financial and Matter Data when you become a client or prospective client of ours;
- Provide us with Identity or Contact Data when you become a contact of ours;
- Opt in to receive information about us, our services and events.
- We may also collect Identity, Contact, Financial and Matter Data about you if you are connected to a client of ours or if you are involved in a matter in respect of which we are instructed. Such data may be collected from our client, their or our agents or from a variety of other sources.
4. HOW WE USE YOUR PERSONAL DATA AND THE LEGAL BASIS
We use your personal data only for the following purposes:
- when it is necessary for the performance of a contract or the provision of a service or in order to take steps prior to entering into a contract or the provision of a service. 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 processing 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 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
- 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 only provide you with marketing related information after you have, where legally required to do so, opted in to receive those communications and having provided the opportunity for you to opt out at any time.
We will not use your personal data for taking any automated decisions affecting or creating profiles.
You can ask us to stop sending you information about us, our services or events at any time by contacting us at firstname.lastname@example.org.
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.
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 third parties including other auditors, accountants, advisers and expert and other specialists, 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 legal and other services to you and/or our client 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 seven (7) years thereafter.
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:
Access: You have the right to access to your personal data and request to receive 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.
Accuracy: It is our objective to keep accurate, current and complete personal data and you have the right to request to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Erasure: You have the right 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objection: You have the right to object to the 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 ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Restriction of processing: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where 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) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
Withdraw consent: You have the right to withdraw 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 you withdraw your 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 rights set out above, please contact us at email@example.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 several requests. In this case, we will notify you and keep you updated.
For any further information, please contact us at firstname.lastname@example.org