We, ASUSPLUS AUDITORS AND TAX CONSULTANTS LTD (the “Firm”), are committed to protecting the privacy and security of the personal data we receive in a transparent manner. The company respects your privacy and is committed to protecting your personal data. This privacy statement will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy statement applies to current and prospective clients that engage our services as well as to any otherwise subjects whose data are collected on a lawful basis and explains why we need to collect and process your data, defines the information we gather, the parameters within which we do so as well as the measures we implement to safeguard them.

The Firm is a data controller. This means that we are responsible for deciding how we hold and use personal data about you in order to comply with applicable law including but not limited to the General Data Protection Regulation (EU) 2016/679) (GDPR), the Protection of Natural Persons with Regard to the Processing of Personal Data and the Free Flow of Such Data Law of 2018 (N. 125(I)/2018) and as they may be amended from time to time.

By providing us with your personal information and using our services, you are accepting and consenting to the practices described herein.

For the purposes of this Privacy Statement

When we refer to “personal data” or “personal information” we mean data which identifies or may identify you and which may include, for instance, your name, address, identification number, telephone number, date of birth, occupation and family status.

When we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data.

Legal basis for processing personal information - why we collect and process your data

We collect and process your personal data in order to:

• Be able to assess your requests and provide you with the best quality of servicing.
• Safeguard your rights and enforce our interests.
• Comply with any legal obligation to which we are subject to.
• Perform our obligations towards our employees in our capacity as employers.

Technical data and cookies

We do not use any cookies or tracking technology on our website.

Direct communication and email correspondence

Where direct communication occurs via email or through our website, we may receive additional information such as contents of the message and/or attachments you may choose to share with us.

We collect and process this information with the purpose of answering your inquiries and providing our services to you as well to safeguard our rights and ensure our legal obligations depending on the circumstances.

Where we store your personal data – Data Retention

We do not transfer your personal data outside the European Economic Area (EEA).

The personal information we collect from you may be stored either on our own servers or with third parties with whom we cooperate and for whom we make sure that they are GDPR compliant.

For further information as to our trusted partners and the retention period please, contact us at info@asuspluscy.com.

Information we collect from you

We will collect and process data about you. Depending on the circumstances, this may include:

• contact / identify information such as your name, job title, postal address, including your home address, where you have provided this to us, business address, telephone number, mobile phone number, fax number, and email address.
• Financial data, such as data necessary for processing payments, including credit/debit card numbers, bank account, security code numbers, and other related billing information such as your specimen signature.
• Information collected from publicly available resources, integrity data bases and credit agencies where this is relevant to the services offered to you.
• identification and background information provided by you or collected by us as part of our business acceptance processes and practices, including, without limitation, any data revealing your ethnic or religious background, marital status, data relating to criminal convictions or health or other data of a sensitive nature legally required in compliance with know your client requirements.
• Information you give to us. This is information that you give us by filling out our client forms, engagement letters, and retainers or by corresponding with us by phone, e-mail, in person or otherwise. It includes information you provide when you choose to use our services and/or become an affiliate/client to our Firm and may include a combination of the above or any other information contained therein.
• Any other information relating to you and your request which you may provide to us or that we may collect.

Uses of the information

We use information held about you in the following ways:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to provide you with information about other services we offer that are similar to those that you have already used or enquired about;
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to notify you about changes to our service; Information we collect about you. We will use this information:
• To comply with other legal obligations (such as record keeping obligations), compliance screening or recording obligations (e.g. for anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party list
• Protecting the security of and managing access to our premises, IT and communication systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
• For insurance purposes.

We combine information about you received by third parties with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above.

Disclosure of your information

You agree that we have the right to share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined under the Cyprus Companies’ Law.
• Selected third parties including:
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  • Business publications and/or legal and/or business directories.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.
  • Credit reference agencies and/or banking/financial institutions for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
  • Compliance software for the purposes of complying with local and international regulations against money-laundering, fraud and the general prevention of crime and illegal activities and/or the cooperation with the authorities and/or the police.

When we will disclose your personal information to third parties

• In the event that this is necessary for the provision of services provided to you.
• If the Firm or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal and/or regulatory obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights or property either ours or that of our customers, or others.

Collection of data under money-laundering policies and procedures

The Firm conducts client due diligence inquiries on each new client and persons connected with them and conducts ongoing monitoring of existing clients. These inquiries are based on applicable legislation. Where necessary for these purposes, we may seek relevant information from third party data suppliers.

Your rights

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

You can exercise your right to prevent such processing by letting us know when we collect your data.

The fundamental data subject rights are:

• Right to Access
• Right to Rectification
• Right to Erasure
• Right to Restrict Processing
• Right to Data Portability
• Right to Object
• Rights in Relation to Automatic Decision Making and Profiling

We would like to note that certain of the above rights may, depending on the circumstances at hand, be limited where we have an overriding interest or legal obligation to continue to process your personal data or where such data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

Don’t hesitate to get in touch with us using the contact details provided towards the end of this Privacy Policy. We reserve the right to ask you for proof of your identity if you contact us as aforesaid.

Access to information

You have the right to be provided and/or access and/or amend and/or rectify information held about you. Under certain conditions, your right of access can be exercised in accordance with the law pending an applicable fee required to meet our costs in providing you with details of the information we hold about you.

Whilst processing a request, the identity of the data subject has to be verified before information is released. We reserve the right to refuse repeated/vexatious requests.

Contact information

If you have any questions in relation to this policy, please contact us at: info@asuspluscy.com

For the purposes of EU Regulation 2016/679, the Data Controller is ASUSPLUS AUDITORS AND TAX CONSULTANTS LTD, of Akropoleos 25, LATITUDES A, Flat/Office 202, Meneou, 7000, Larnaca, Cyprus.