We collect and process personal data such us name, surname, telephone number, address, email, identification data, employment, source of income, source of funds/wealth, bank account details.
We collect personal data by data subjects either directly or through their representative or different channels of communication (i.e. contact form in our website).
We may also collect and process personal data which we lawfully obtain from third parties such us public authorities, introducers, partners, associates etc or from publicly available sources such as the Deparmtnet of the Registrar of Companies and Official Receiver or the internet.
Processing of personal data takes place to enable us to proceed with the setup of a business relationship with you or a related person (i.e. a legal entity of which you are the UBO, authorized person, employee, agent or other representative) and to subsequently provide our (legal) services to you.
We are furthermore obliged to collect and process personal data in order to comply with all applicable AML laws/regulations.
We collect and process personal data for one or more of the following reasons:
Contract performance
We process personal data in order to provide our services based on contracts with our clients or others but also to be able to enter into a contract with prospective clients or others.
Complying with legal obligations
We process personal data to comply with our professional duties and legal obligations emanating, amongst others, from the AML laws/regulations.
Safeguarding legitimate interests
We process personal data to safeguard the legitimate interests pursued by us or by third parties. Examples of such processing activities include:
We may process personal data if you have given us your consent to do so. You have the right to revoke your consent at any time. Any processing of personal data prior to the receipt of your revocation will not be affected.
In the course of the performance of our contractual and statutory obligations, your personal data may be provided to various employees of A. BILLIS LLC as well as associates of A. BILLIS LLC such us external associate lawyers, accountants, auditors, fiduciary services providers etc.
Receivers of personal data may also be supervisory and other regulatory authorities as well as public authorities, as may be required.
We also note that we may disclose your personal data for any of the reasons set out abov, or if we are legally required to do so or if we are authorized under our contractual and statutory obligations or if you have provided us with your respective consent.
In order to be able to start or maintain a business relationship with you, you must provide us with your personal data, which shall be necessary for the performance of our contractual obligations.
Please note that if you do not provide us with the required data, we will not be able to start or maintain a business relationship with you or any other relevant person.
It is hereby noted that your personal data shall be properly provided to us upon the agreement of our services and/or the execution of the corresponding Engagement Letter for the agreed services.
Your personal data may be transferred to third countries, namely countries outside of the European Economic Area and/or the European Union, if such data transfer is required by law (i.e. reporting obligation of ours under law) or if you have given us your consent to do so.
Processors in third countries are obligated to comply with the European data protection standards and to provide appropriate safeguards in relation to the transfer of your personal data.
We will maintain your personal data in our records for as long as we maintain a business relationship with you and for 5 years following the termination of such, or in any other way end and/or completion of such.
In case so required, we may keep your personal data for longer than the above mentioned period.
Access right
You have the right to access your personal data and be informed as to whether or not your personal data is being processed. You have the right to receive a copy of the personal data of yours we hold and to check that we are lawfully processing it.
Rectification right
You have the right to have any incomplete or inaccurate data of your that we hold rectified.
Erasure right
You have the right to require us to erase your personal data in case there is no good reason for us to continue processing it.
However, we reserve the right to deny sucherasure, in case the processing of personal data is necessary for compliance with a legal obligation, for public interest reasons or for the establishment, exercise or defence of legal claims.
Data portability right
You have the right to receive your personal data, in a structured and commonly used way, and to transfer such data to a third party under particular circumstances.
Objection to processing right
Where we are relying on a legitimate interest, you have the right of objection to processing. Once you lodge such an objection, we will no longer process your personal data, unless we demonstrate compelling legitimate grounds for the processing which may override such a right of yours.
Restriction of processing right
You are entitled to ask us to restrict the processing of your personal data, namely to use it only for certain matters, in case: a) it is innacurate; b) it has been used unlawfully but you do not wish for us to delete it; c) it is not relevant any more, but you want us to keep it for use in possible legal claims' or d) you have already asked us to stop using your personal data, but you are waiting our confirmation on whether we have legitimate grounds to keep processing such.
Withdrawal of consent right
You are entitled to revoke your consent at any time. The lawfulness of any processing of your personal data prior to the receipt of your revocation request shall not be affected.
To exercise any of your rights or if you have any other queries about the use of your personal data, please contact us at info@billisllc.com.
If you have exercised any or all of your data protection rights as per above and still feel that your concerns about our usage of your personal data have not been adequately addressed, you shall be entitled to complain to the Office of the Commissioner for Personal Data Protection (http://www.dataprotection.gov.cy).
We may modify and/or amend this privacy policy from time to time. In that respect, we encourage you to periodically check the present Policy for any changes and/or amendments and/or modifications that may have taken place and may be of material concern for your interests.
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