CAFMAN LIMITED (“CAFMAN”, “we”, “us” or “our” in this Privacy Policy) respects your privacy and the protection of the security and confidentiality of your personal data is of outmost importance to us. This Privacy Policy 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 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.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy 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 Policy supplements any other notices and is not intended to override them.

1. WHO WE ARE

CAFMAN LIMITED, a duly registered limited liability company in Cyprus under the registration number ΗΕ405206, is an Administrative Services provider in Cyprus. Our website address is: https://cafman.cy/

If you have any questions about this Privacy Policy or want more details about how we use your personal information, you can contact our team who will gladly refer you to a specialist at info@cafman.cy.

2. WHAT 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 by using cookies.
  • 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 DO WE COLLECT YOUR PERSONAL DATA

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.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect technical data by using cookies.

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;
    • 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.
  • 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 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. for tax purposes, 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. This can include sharing your personal data with third parties, such as the competent law enforcement authorities.
  • 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 info@cafman.cy.

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.

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. WHO WE SHARE YOUR PERSONAL DATA WITH

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. HOW LONG WE RETAIN YOUR PERSONAL DATA

We will only retain your personal data for as long as necessary to fulfill 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.

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.

7. WHAT LEGAL RIGHTS YOU HAVE OVER YOUR PERSONAL DATA

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.
  • Right to Rectification: It is our objective to keep your personal data accurate, current and complete.
  • Right to Erasure: You have the right to ask us to delete your personal data where there is no reason to continue processing it.
  • 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.
  • Right to Restrict Processing: You have the right to ask us to suspend the processing of your personal data.
  • Right to Data Portability: You have the right to request the transfer of your personal data to you or to a third party.
  • 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.

If you wish to exercise any of the rights set out above, please contact us at info@cafman.cy.

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.

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.

8. ADDITIONAL INFORMATION 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 strongly advise you to review the privacy policy and terms and conditions of every website you visit.

We have no control over these third-party websites, and assume no responsibility for the content, privacy policies or practices of any third-party websites, products or services.

CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

Although most changes are likely to be minor, CAFMAN may change this Privacy Policy from time to time, and in CAFMAN’s sole discretion. CAFMAN encourages visitors to frequently check our website (https://cafman.cy/) for any changes to this Privacy Policy. Your continued use of our website after any change in this Privacy Policy will constitute your acceptance of such 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.