Elena Chr. Mina & Co LLC (the “Firm”) is committed to protecting privacy and making sure that any personal data it collects are processed in accordance with the EU General Data Protection Regulation (the “GDPR”) and applicable Cyprus laws and regulations. References in this policy to “we”, “us” and “our” are references to the Firm. References to “you” and “your” are to the individual/s who is/are providing personal data to us.

We may amend or update this Privacy Policy from time to time. All amendments or updates will be posted on the Firm’s website at: www.ecmlaw.com.cy (the “Website”). We encourage you to periodically review our Privacy Policy to be informed of how we are committed to protecting personal data.

Scope of Private Policy

This Privacy Policy describes our approach to any personal information that we may collect from you, or via a third party about you, and the purposes for which we process such data. It also sets out your rights in respect of our processing of your personal data.

This Privacy Policy sets out what kind of personal information we process and how you can request for us to delete, update, transfer and/or provide you with access to personal information pertaining to you.

Personal Data Collection

We collect personal information in a number of circumstances, including:

• when you contact us to seek legal advice or services from us;
• when you make an enquiry via the Website or by email;
• when you offer to provide or provide goods or services to us;
• information collected, via the Website, using cookies, unless you have disabled cookies (see relevant section below).

In some circumstances, we may collect personal data about you from a third-party source. For example, we may collect personal data from your organisation, other organisations with whom you have dealings, to include banks and other professional service providers or other organisations in the context of the provision of our services to you or generally in the context of any other dealings we may have with you. In any case, such collection from third parties is always carried out in line with our legal obligations.

Types of Personal Data We Collect

Depending on the circumstance, we may collect the following data:

• Personal Details, such as your name, date of birth, personal contact details (postal address, email address, telephone number, fax), job title/profession and/or job description;
• Identification Information, such as ID number and/or passport number;
• Payment Data, such as data necessary for processing payments to include bank account details, details of beneficiaries and other related billing information;
• Further information necessarily processed in a project or client contractual relationship with the Firm or voluntarily provided by you, such as instructions given, payments made, requests that you address to us.
• Special categories of personal data (sensitive data): In connection with the provision of legal services to you, we may on some occasions need to ask for certain sensitive information (e.g. information about your health etc.). The processing of sensitive data will only be carried out by us in full compliance with the GDPR and applicable national legislation, on the basis of your explicit prior consent.
• Details of your visits to our premises.

Purposes and Legal Bases for the Processing of Personal Data

The Firm uses your Personal Data for the purposes for which you have supplied it to us, to include:

• for responding to your requests for legal advice and/or other enquiries;
• for providing legal advice and/or other corporate and/or administrative services you may have requested;
• for ensuring compliance with our legal obligations (e.g. for compliance with our obligations under applicable anti-money laundering laws);
• for complying with court orders and/or defending our legal rights, where applicable;
• for any other purpose for which your personal data were provided to us;

Our main legal bases for the processing of your personal data are the following:

• the processing is necessary for the performance on our part of the contract concerning the provision of legal services to you or to take steps at your request prior to entering into such contract, or the processing is necessary for the performance of any other contract or generally in the context of any other dealings we may have with you;
• the processing is necessary for us to comply with a legal obligation (for example under applicable Anti-Money Laundering laws);
• the processing is in our legitimate interests and our interests are not overridden by your interests, fundamental rights or freedoms;

Our legal bases for the processing of special categories of personal data (sensitive data) are the following:

• you have provided your explicit consent to the processing of such sensitive personal data for specified purposes;
• processing of such data may be necessary for the establishment, exercise or defence of legal claims.

Sharing Your Personal Data

We will not disclose your personally data, except:

• to third parties who provide services on our behalf, e.g. third parties providing document management services or software developers;
• to collaborators, to include instructing counsel, banks, accountants and auditors;
• where we are required to do so by law or where it is necessary for the purpose of, or in connection with, legal proceedings or in order to exercise or defend legal rights;
• upon your instructions or your express consent.

We may also share your personal data with any third party to whom we assign any of our rights or obligations.

Personal data about other individuals which you provide to us

If you provide us with personal data about another individual, you must ensure that you are entitled to disclose such personal data to us and that you have provided the relevant data subjects of all mandatory data privacy notifications and information under the GDPR and applicable legislation and regulations, to include a notification as to their legal rights as data subjects. For that purpose, you must also ensure that the individual concerned is aware of the contents of the present Privacy Policy, as those matters relate to that individual, to include our identity, how to contact us, the purposes of collection of the data, how we may use and/or share the data and his/her relevant rights.

Cookies

The Website use cookies to identify your computer when you are on the Website. A cookie is a file sent by the Website to your computer, and used by the Website to identify you, to improve the site and to deliver a personalised service.
You may configure your browser to refuse or restrict the use of cookies. Please note that you may not be able to use the Website properly if your browser is configured not to allow cookies.

Personal Data Retention Period

We retain your relevant personal information for at least six (6) years from the date of our last interaction, in compliance with our obligations under the EU General Data Protection Regulation and/or related national and international legislation, or for longer if we are required to do so by our regulatory obligations and/or professional indemnity obligations. Unless we hear from you by the end of such a period, we destroy the relevant personal data without further notice and/or liability.

Security and Confidentiality of your Personal Data

We are committed to protecting the personal information provided to us; to this end, we have implemented information security policies, rules and technical measures to protect the personal information data under our control from unauthorised access, improper use and/or disclosure, unauthorised modification and/or unlawful destruction and/or accidental loss.

Your Rights

You may find below a list of your legal rights insofar as your personal data are concerned. Please note that some of these rights may not be applicable to your situation.

• You have the right to gain access to the personal data that we hold about you.
• You have the right to request the correction, without undue delay, of any personal data that we hold about you and are either inaccurate or incomplete.
• You have the right to request the erasure of your personal data, without undue delay, provided, amongst others, the personal data in question are no longer necessary in relation to the purposes for which they were collected.
• You have the right to restrict our processing activities or to object to the processing of your personal data.
• You have the right to request from us that we send your personal data in a structured, commonly used and machine-readable format, and to transmit those data to another controller.
• If we rely on your consent as our legal basis for the processing of your personal data, you have the right to withdraw that consent at any time.

How to contact us

If you wish to exercise any of your above-mentioned rights or have any questions or comments with regard to this Privacy Policy, you may contact us by email at info@ecmlaw.com.cy or by post at Elena Chr. Mina & Co LLC, 31 Evagorou Avenue, Evagoras Complex, Office 33 1066 Nicosia, Cyprus.

In addition to the above, you also have the right to lodge a complaint to the Office of the Commissioner for Personal Data Protection in Cyprus.