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PRIVACY STATEMENT
Last update: 12 June 2018

Introduction

Privacy Statement Summary 

This Privacy statement describes when and what personal data we gather about you, how we use such personal data, and who we give such personal data to. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection. It also sets out your rights in relation to your personal data and who you can contact for more information or queries.

Personal data includes any information relating to an identified or identifiable individual.  AuditPro processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

You can find how we will collect, handle, store and protect personal information about you when providing services to you or to our clients, when you use “the AuditPro Website”, or when we perform any other activities.

The privacy statement set below, applies to personal data processed by AuditPro Services Limited, registered in Cyprus under registration number 155999 with registered office address at 28 Oktovriou Avenue No. 1, Engomi Business Centre, Block B, Office 104, 2414 Egkomi, Nicosia, Cyprus.

Please refer below for specific information to the various provisions of this privacy statement:
  1. What information we collect?
  2. How we use information about you?
  3. Who we disclose your information to?
  4. Protection of your personal information
  5. How long we keep your information for?
  6. Your rights
  7. Changes to this privacy statement
1. What information do we collect and where do we collect it from?

In the course of providing services to you as a client and particularly when performing due diligence checks in connection with our services (or discussing possible services we might provide to you as a prospective client), we may collect or obtain personal data about you.  We may also collect personal data from you when you use our Website.

We may collect or obtain such data because you give them to us (for example in a form on our Website or through our “know-your-client” procedures), because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.

We may also collect or obtain personal data from you because we observe or infer that data about you from the way you interact with us.
The personal data that we collect or obtain may include without limitation: your name; age; date of birth;  ID number; e-mail address; home address; country of residence;  family circumstances (for example, your marital status and number of dependents); employment and education details (for example, the organization you work for, your job title and your education details); financial and tax-related information (for example your income and tax residency); your IP address; your browser type and language; your access times; complaint details;  and other similar information.

The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you, for example as a result of legal requirements imposed on us.

Where we have no direct contractual relationship with you but obtain your personal data about you by our client, we take steps to ensure that the client has complied with the privacy laws and regulations relevant to that information; this may include, for example, that the client has provided you with the relevant information notices in relation to how your personal data will be processed and disclosed to third parties and has obtained any necessary consents for us to process your personal data as described in this privacy statement and/or our engagement with the client.

We understand the importance of protecting children's privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children. For the purposes of this privacy statement, “children” are individuals under the age of eighteen.
By registering and/or submitting personal information to AuditPro, you are also acknowledging that AuditPro may use this information in accordance with this Privacy Statement.

2. How we use information about you?

Use of personal information to provide services to our clients

We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

2.1   Where we need to perform the contract we have entered with you or in order to take certain steps prior to entering into a contract with you.

We will use your personal data to provide you with our services. As part of this, we may use your personal data in the course of correspondence relating to the services.  Such correspondence may be with you and our service providers or competent authorities.  We may also use your personal data to conduct due diligence checks relating to the services.

Because we provide a wide range of services to our clients, the way we use personal data in relation to our services also varies. For example, we might use personal data:
  • administering, managing and developing our businesses and services,
  • about a client’s employees to help those employees manage their tax affairs when working overseas,
  • when we offer human capital services (such as payroll services),
  • about a client’s employees and customers in the course of conducting an audit (or similar activity) for a client,
  • about a client to help him/her complete and submit a tax return,
  • when we consider applicants for employment purposes,
  • when we provide risk advisory services to corporate clients, or
  • when we provide investment services to clients (such as investment advice).
If you do not provide the personal data we request from you, we may not be able to offer or continue offering our services to you.

2.2   Where we need to comply with a legal obligation

We are required to comply with certain legal and regulatory obligations, as well as certain industry standards, which may involve the processing of personal data. We may, for example, need to carry out identity verifications through our “know-your-client” procedures, set-up anti-money laundering controls and comply with our tax reporting obligations. We may also need to provide information to a public body or law enforcement agency when we are so required.

2.3   Where we have appropriate legitimate interests to use your personal data

In some cases, we may process your personal data to pursue business interests of our own or of third parties, provided your interests and fundamental rights do not override such interests. More specifically, we process your personal data:
  • to maintain our accounts and records,
  • to enhance the security of our network and information systems,
  • to identify, prevent and investigate fraud and other unlawful activities,
  • to safeguard the security of our people, premises and assets and prevent trespassing through video surveillance,
  • to manage our infrastructure, business operations and comply with internal policies and procedures,
  • for financial accounting, invoicing and risk analysis purposes,
  • to modify, personalize or otherwise improve our services,
  • to defend, investigate or prosecute legal claims,
  • for recruitment and business development purposes, and
  • in order to receive professional advice from our advisors including our lawyers, accountants and consultants.
2.4   Where you have given us your consent

We will only ask for your consent when we wish to provide marketing information to you in relation to our products and/or services that we think might be of interest to you.  If you give us your consent, we may also contact you for market or research purposes from time to time.
You may withdraw your consent to such processing at any time by contacting privacy@auditproservices.com.

3. Who we disclose your information to?

In connection with one or more of the purposes outlined in this privacy statement, we may disclose details about you to: third parties that provide services to us; competent authorities (including courts and authorities regulating us); your employer and/or their advisers; your advisers; credit reference agencies or other organisations that help us make business decisions and mitigate the risk of potential fraud and misconduct and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in this privacy statement.

4. Protection of your personal information

We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
  • education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
  • administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
  • technological security measures, including firewalls, encryption and anti-virus software; and
  • physical security measures to access our premises. 

5. How long we keep your information for?

We will hold your personal data on our systems for the longest of the following periods:
  1. as long as is necessary for the relevant activity or services,
  2. any retention period that is required by law,
  3. the end of the period in which litigation or investigations might arise in respect of the services, or,
  4. in the absence of specific, legal, regulatory or contractual requirements, our base line retention period for records and other documentary evidence created in the provision of services is seven (7) years.
6. Your rights

You have various rights, under the Data Protection regulation, in relation to your personal data. In particular, you have a right to:
  • Receive access to your personal data. You may request to obtain from ourselves a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction [rectification] of the personal data about you which we process. This provides you with the opportunity to have any incomplete or inaccurate data we hold and process about you, completed and/or corrected.
  • Request deletion of your personal information. This right provides you with the opportunity request from us to delete personal data concerning you [known as the ‘right to be forgotten] where there is no good reason for us to continue to process it. Additionally, you also have the right to ask us to delete your data where you have exercised your right to object to processing (see Object to processing below).
  • Object to processing of your personal data, including profiling, 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. You also have the right to object where we are processing your personal data for direct marketing purposes.  If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
  • Request the restriction of processing of your personal data. With this right you are able to ask us to suspend the processing of your personal data if:
- The said data is not accurate,
- it has been used unlawfully but you do not wish for us to delete it,
- it is not relevant any more, but you want us to keep it for use in possible legal claims, or
- you have already asked us to stop using your personal data but you are waiting for us to confirm if we are allowed to keep using it.
  • Request to receive a copy of your personal data in a format that is structured and commonly used and transfer such data to other organisations. You may request the transfer of your personal data directly by us to other organizations [data portability]
  • Withdraw your consent with regard to the processing of your personal data for certain purposes at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing which was based on consent before it was withdrawn or revoked by you.
  • To complain if you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Office of the Commissioner for Personal Data Protection in Cyprus.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please send an email to privacy@auditproservices.com or write to us to the address below:

The Data Protection Officer
AuditPro Services Limited
P.O. Box 25552
1310 Nicosia
Cyprus
 
7. Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

To let you know when we make changes to this privacy statement, we will amend the revision date at the top of the first page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.
"AuditPro Services" refers to AuditPro Services Ltd, a limited liability company registered in the Republic of Cyprus Reg. No. 155999
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