WHO WE ARE

Vryonidou, Anastasiadi & Philippou LLC (“VAP”, “we”, “us”, “our”) is a lawyers’ limited liability company registered in the Republic of Cyprus under the name Vryonidou, Anastasiadi & Philippou LLC, registration number HE 485907, with its registered office at Stasandrou & Grigoriou Xenopoulou 7, Eleniko, Floor 2, Office 203, 1060 Nicosia, Cyprus.

We are advocates regulated by the Cyprus Bar Association.

We are the data controller for the personal data described in this policy.

You can contact us about this policy, or about your personal data, at:

• Email | info@vaplawfirm.com

• Telephone | +357 22 522 470

• Post | Stasandrou & Grigoriou Xenopoulou 7, Eleniko, Floor 2, Office 203, 1060 Nicosia, Cyprus

SCOPE

This policy explains how we collect and use personal data when you visit vaplawfirm.com, when you contact us, and when we act for you or for an organisation you represent. It also explains your rights and how to exercise them. We process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation) and the Cyprus Law Providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018).

THE PERSONAL DATA WE COLLECT

• Information you give us: When you submit an enquiry through our website: your name, your email address,
  your telephone number if you provide one, the category of your enquiry, and anything you choose to write in the message field.

• When you contact us by email, telephone or post: the contact details you use and the contents of your communication.

• When we act for you: the information necessary to provide legal services. Depending on the matter this may include identification and verification documents, financial information, correspondence, and information about third parties connected with the matter. In some matters this will include special categories of personal data — for example information relating to health — or personal data relating to criminal convictions and offences.

• Information we collect automatically: When you visit our website we may collect technical information including your IP address, browser and device type, the pages you visit and the time of your visit.

• Information we receive from others: We may receive personal data about you from other parties to a matter and their advisers, from courts, public registers and public authorities, and from identity verification and screening services used for client due diligence.

WHY WE USE PERSONAL DATA, AND OUR LEGAL BASIS

• Responding to your enquiry: Our legitimate interests in responding to people who contact us, and, where the enquiry may lead to instructions, taking steps at your request before entering into a contract.

• Providing legal services: Performance of our contract with you. Where the matter involves special categories of personal data, we rely on the establishment, exercise or defence of legal claims.

• Client identification and anti-money laundering checks

• Compliance with our legal obligations.

• Conflict checking before accepting instructions

• Our legitimate interests and our professional obligations.

• Billing, accounting and record keeping

• Compliance with our legal obligations, and our legitimate interests in running the practice.

• Operating and securing our website

• Our legitimate interests in keeping the site available and secure.

Where we rely on legitimate interests, those interests are the effective, secure and compliant operation of a legal practice. We have considered whether those interests are overridden by your interests and rights, and concluded that they are not. You may object to this processing — see section 10.

CLIENT IDENTIFICATION AND ANTI-MONEY LAUNDERING

As advocates we are subject to the Prevention and Suppression of Money Laundering and Terrorist Financing Laws of Cyprus and to directives issued by the Cyprus Bar Association. Before we can act, we are required to identify and verify our clients and, where relevant, beneficial owners and persons acting on a client’s behalf, and to keep records of that verification. We may be required to report certain matters to the competent authorities. In some circumstances the law prohibits us from telling you that a report has been made.

COOKIES

Our website uses cookies and similar technologies. Cookies that are strictly necessary for the site to function are set automatically. Any non-essential cookies, including analytics cookies, are set only with your consent, and you may withdraw that consent at any time.

WHO WE SHARE PERSONAL DATA WITH

We may share personal data with:

• Courts, tribunals, other parties to a matter and their advisers, where this is necessary to conduct the matter; Advocates, barristers, experts, agents and foreign lawyers instructed in connection with your matter; Regulators, public authorities and law enforcement, where we are required or permitted to disclose;

• Our professional advisers, auditors, bankers and insurers;

• Service providers who process personal data on our behalf under contract, including our website host, and our IT and email providers.

We do not sell personal data, and we do not use it for automated decision-making that produces legal effects concerning you.

TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA

Some of our service providers may process personal data outside the European Economic Area. Where that occurs, we ensure an appropriate safeguard is in place, such as an adequacy decision of the European Commission or standard contractual clauses approved by the Commission. You may request details of the safeguard applied.

HOW LONG WE KEEP PERSONAL DATA

We keep personal data only for as long as we need it for the purposes set out in this policy, and to meet our legal and regulatory obligations.

• Enquiries that do not result in instructions - [TBC]

• Client files after a matter concludes - [TBC]

• Anti-money laundering records - For the minimum period required by law after the end of the business relationship or completion of the transaction [TBC — confirm period]

• Accounting and tax records - As required by Cyprus tax and companies legislation.

When personal data is no longer required, we delete it or securely destroy it.

YOUR RIGHTS

Subject to the limits described below, you have the right to:

• ask for a copy of the personal data we hold about you;

• ask us to correct personal data that is inaccurate or incomplete;

• ask us to erase personal data;

• ask us to restrict how we use your personal data;

• object to processing that we carry out on the basis of legitimate interests;

• receive certain personal data in a portable format, or ask us to transmit it to another controller;

• withdraw your consent at any time, where we rely on consent. Withdrawing consent does not affect processing carried out before you withdrew it.

These rights are not absolute. In particular, we may be unable to comply with a request where the personal data is subject to legal professional privilege, where we are required by law to retain it, or where it is needed for the establishment, exercise or defence of legal claims. If we cannot comply with a request, we will tell you why.

To exercise any of these rights, contact us using the details in section 1. We will respond within one month. If your request is complex we may extend that period, and we will tell you if we do.

COMPLAINTS

If you are concerned about how we have handled your personal data, please contact us first so that we can try to resolve it. You also have the right to complain to the supervisory authority in Cyprus:

Office of the Commissioner for Personal Data Protection

www.dataprotection.gov.cy

SECURITY

We maintain technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration and loss. Our advocates and staff are bound by professional obligations of confidentiality that continue after our engagement ends. Please note that email is not a secure medium. Do not send confidential or sensitive information to us by email, or through the enquiry form on this website, before we have agreed a secure means of communication with you.

CHANGES TO THIS POLICY

We may update this policy from time to time. The date at the top of this page shows when it was last updated. Where changes are significant, we will take reasonable steps to bring them to your attention.

CONTACT

Vryonidou, Anastasiadi & Philippou LLC
Stasandrou & Grigoriou Xenopoulou 7, Eleniko, Floor 2, Office 203
1060 Nicosia, Cyprus

info@vaplawfirm.com
+357 22 522 470