TERMS OF USE OF WEBSITE
PRIVACY POLICY
This Privacy Policy are the rules of storage and processing of your personal data in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), the Article 13 “Professional secrecy” of the Advocates’ Code of Conduct Regulations of 2002 and the provisions of the Law for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018).
OLGA L. PSHENICHNAYA & CO LLC (or 'we', 'us,' 'our'), is the Controller in accordance with the Regulation (EU) 2016/679 (GDPR) due to being supervised by the Cyprus Bar Association and shall bear the obligations of Controller in accordance with the Regulation (EU) 2016/679 (GDPR).
Personal Data Collection
We collect Personal Data which is provided by visitors directly or by any authorized by visitors third persons or from available sources for specified, explicit and legitimate purposes, purposes of ordering of our services.
Processing of Personal Data
Confidentiality regime by engaged persons
Processing of Personal Data we shall ensure that confidentiality regime is observed by our specialists, consultants, auditors, and any other persons engaged and pursuant to the Article 32(4) of the Regulation (EU) 2016/679 (GDPR) we shall take steps to ensure that any natural person acting under our authority who has access to personal data does not process it except on our instructions, unless he or she is required to do so by Union or Member State law.
Transfer of Personal Data
We may transfer our customers’ Personal Data upon the request of competent state authorities or under the requirement by law, or if the relevant data is already in the public domain and /or upon the request of financial organizations, insurers, lawyers, auditors and other agents, for whose intermediary services was obtained consent or order from our customers.
Transfer of Personal Data to countries outside the EU and/or the European Economic Area (EEA)
The Personal Data may not be transferred to countries outside the EU and/or the European Economic Area (EEA) without our prior written consent as Controller. If Personal Data processed is transferred from a country within the European Economic Area to a country outside the European Economic Area, the Processor and we as Controller shall ensure that the Personal Data are adequately protected. To achieve this, the Processor and we as Controller shall, unless agreed otherwise, rely on EU approved standard contractual clauses for the transfer of Personal Data.
We may transfer our customers’ Personal Data to countries outside the EU and/or the European Economic Area (EEA) if
The exceptions are:
1. The customer has given his or her explicit consent to the restricted transfer, Art. 49 (1)(a).
2. We have or about to enter into a contract with the customer and the restricted transfer necessary for us to enter into Art. 49 (1)(b) or perform that contract Art. 49 (1)(c) (orders, services etc.).
3. We need to make the restricted transfer for important reasons of public interest, Art. 49 (1)(d).
4. We need to make the restricted transfer to establish a legal claim, to make a legal claim or to defend a legal claim, Art. 49 (1)(e).
5. We need to make the restricted transfer to protect the vital interests of a customer in case if a customer is physically or legally incapable of giving consent, Art. 49 (1)(f).
6. We are making the restricted transfer from a public register, Art. 49 (1)(g).
7. We are making a one-off restricted transfer, which is our compelling legitimate interest, Paragraph 2, Art. 49.
Storage of Personal Data
Pursuant to the Recital 39 of the Regulation (EU) 2016/679 (GDPR), the Article 68 of Cyprus Prevention and Suppression of Money Laundering and Terrorist Financing Law 2007 (188/(I)2007) as amended up until 2019 we shall safekeep Personal Data of our customers whose data is to be stored and processed, within 5 years after the date of cessation of any Services and promptly and in any event delete all originals and copies of those Personal Data after 5 years following the cessation of Service, and in accordance with the Article 68 of Cyprus Prevention and Suppression of Money Laundering and Terrorist Financing Law 2007 (188/(I)2007) as amended up until 2019 we shall safekeep all records and documents related to the Company within 5 years after the date of cessation of any Services and promptly and in any event delete all originals and copies of those Data after 5 years following the cessation of Service and in accordance with the Article 141 of the Company Law, Cap. 113 and the Article 43 of the 10th Annex of the Value added tax Law of 2000 we being the Director of any Company of our customer shall safekeep accounting books and files of the Company within 6 years after the date of cessation of any Services and promptly and in any event delete all originals and copies of those Data after 6 years following the cessation of any Services.
The rights of the customers
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COOKIE POLICY