GDPR Privacy Policy

K.P.S. SERVICES LIMITED PRIVACY STATEMENT

In our efforts for a transparent processing of the personal data of existing or prospective clients we provide below our Company Policy as this is implemented in compliance to the EU General Data Protection Regulation “GDPR”.

1) Who is K.P.S. Services Ltd?

K.P.S. Services Ltd is a licensed fiduciary provider by the Institute of Certified Public Accountants of Cyprus (ICPAC).

The Company operates under the registration number HE115777 with its registered office at 3A Patriarchi Gregoriou, Elioupoli, Dhali, 2540 Nicosia.

Whenever you want any assistance or clarification regarding your personal data, please contact us at our email info@kps.com.cy

2) Type of personal data collected and methodologies of collecting it.

We use various processes and methodologies when collecting personal data from our existing or prospective clients.

This is usually done either in person, via our website or via various channels of communication like email and fax.

Other methodologies of collecting personal data includes obtaining data from public sources like the Registrar of Companies, the Land Registry, various media sources, the press and the internet.

3) If you are a prospective customer the following personal data will be collected before entering into an official agreement/business relationship with K.P.S. Services Ltd.

a) Full name

b) Residential and business address

c) Telephone and email

d) Date and place of birth

e) Status of employment

f) ID or passport copy

4) Upon entering into a legal business relationship with K.P.S. Services Ltd, the following additional data will be requested and processed including the following:

a) Source of wealth i.e. economic and financial background

b) CV

c) Tax residence and corresponding Tax number

d) Credit reference agency data like World Check and Lexis Nexis

e) Bank reference

f) Accountant or Lawyer reference letter

g) Employment position and employer certificate of work

5) Are you obliged to provide us with your personal data?

In the cases whereby current or prospective clients do not have all the underlying data submitted to our firm enabling us to start or continue a business relationship, then K.P.S. Services Ltd, will be in bridge of the provisions of the Anti-Money Laundering Law enforcing us in immediate termination of our business relationship or in the case of a new client we will not be able to commence our business cooperation.

6) What are the reasons that K.P.S. Services Ltd collects and processes your personal data.

Fiduciary licensed providers collect personal data of prospective or existing clients for numerous reasons including the following:

  1. To initiate and continue a business relationship with a client based on contract’s requirements and obligations
  2. To meet the requirements on KYC data collection as required by our supervisory body ICPAC
  3. To meet the requirements as these are defined by the law of 2007, 2010, 2012 and 2013 “Prevention and Suppression of Money Laundering and Terrorist Financing”
  4. To meet the requirements as these are set by the Tax Laws and any court orders
  5. To safeguard our legitimate interests
  6. To ensure that the client’s data were submitted to us with their consent for processing and to inform them of their right to revoke their consent at any time they wish

7) Does K.P.S. Services Limited share its’ clients personal data?

In various cases our Company shares its client’s data within the Company Departments and in some instances it may share its customer’s data with various 3rd parties.

We ensure that these parties are obliged to follow the GDPR provisions and law as described above.

A sample list of these parties is given below:

  1. Credit reference agencies
  2. Legal and professional consultants
  3. Bank institutions for bank account opening and maintenance
  4. Marketing consultants for in-house processing
  5. Fraud prevention companies
  6. Companies providing storage facilities
  7. Website consultancy companies
  8. Any other 3rd party as deemed necessary on customer requirements and contract obligations
  9. Other companies or organizations located in a 3rd country outside the European Economic Area as this is required either by law or with your consent. These companies or organizations implement GDPR data as per Article 46 and is mandatory.

8) For how long does K.P.S. Services Limited keep it’s’ clients personal data?

As per the directive of the Data Protection Commissioner for business relationships that have ended we may keep the client’s personal data for 10 years.

In the case whereby data were collected by a prospective client but the parties did not engage into a business relationship we may keep again the prospective client’s data for 6 months from the date we notified the client or the client decided not to proceed (http://www.dataprotection.gov.cy)

For clients continuing to have a business relationship with our firm we may keep their personal data as long as there is a business relationship in effect.

9) What are your personal data protection rights?

As per GDPR guidance on holding personal data of our customers they have the following rights:

  1. Clients may access their personal data any time they require
  2. Client may ask us to correct his/ her data he finds incorrect or incomplete
  3. Client may ask to delete personal data that are not deemed necessary for the business relationship in place
  4. Client may deny further processing of his data which in turn will mean immediate termination of the underlying business relationship
  5. Client may object in terms of his data being processed for in-house marketing purposes
  6. Client may request at any time a copy of his data in a common format and also the client may ask to share that information with any other Company he wishes (right to data portability)
  7. Client at any time may withdraw his consent of our firm processing his/ her personal data

If you wish to exercise any of your right or make a complaint please contact us at info@kps.com.cy.

10) Cookies

Our website uses cookies and we suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

Website Privacy Policy

Effective date: May 16, 2018

K.P.S. Services Ltd (“us”, “we”, or “our”) operates the https://kps.com.cy/ website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://kps.com.cy/

Definitions

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data Controller

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Company name
  • Chat transcript
  • Cookies and Usage Data

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

K.P.S. Services Ltd uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues

Retention of Data

K.P.S. Services Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

K.P.S. Services Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Cyprus and choose to provide information to us, please note that we transfer the data, including Personal Data, to Cyprus and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

K.P.S. Services Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

Disclosure for Law Enforcement

Under certain circumstances K.P.S. Services Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

K.P.S. Services Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of K.P.S. Services Ltd
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Rights

K.P.S. Services Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the right:

  • To access and receive a copy of the Personal Data we hold about you
  • To rectify any Personal Data held about you that is inaccurate
  • To request the deletion of Personal Data held about you

You have the right to data portability for the information you provide to K.P.S. Services Ltd. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.

Please note that we may ask you to verify your identity before responding to such requests.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Behavioral Remarketing

K.P.S. Services Ltd uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

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

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • By email: info@kps.com.cy
  • By visiting this page on our website: https://kps.com.cy/contact/
  • By phone number: +357 22 750900
  • By mail: 30 Costa Anaxagorou Str. & Limassol Avenue, Office 101, 2014 Nicosia, Cyprus