Effective Date: from 25 May 2018
This Privacy Policy aims to explain how LABS collects, uses and discloses your personal data, and your rights in relation to the personal data it holds.
HQ LIFE & BUSINESS SOLUTIONS (LABS) LTD (in this Privacy Policy, “LABS”, “us”, “we” and “our”) is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”).
How LABS collects your personal data:
We collect your personal data in a number of ways, for example:
- From the information you provide to us in person during meetings in our office or any other place;
- From information about you provided to us by your company or an intermediary;
- When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication for improvement of quality and training purposes;
- When you complete applications or other forms;
- From our partners – legal, accounting, audit and other professional organisations which we provide our services;
- From your agents, advisers, intermediaries, and custodians of your assets;
- From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.
What kind of personal data LABS collects:
Personal data means any information relating to an identified or identifiable natural person. We collect the following categories of personal data about you:
- Your name and contact information such as your home or business address, email address and telephone number;
- Biographical information which may confirm your identity including your date of birth, marital status, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality;
- Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details and criminal records;
- An understanding of your goals and objectives in procuring our services;
- Information about your employment, education, family or personal circumstances, and interests, where relevant;
- Information to assess whether you may represent a politically exposed person or money laundering risk;
- Additional information which we may require to collect within Anti-Money Laundering and Counter Terrorism Financial legislation.
How does LABS use personal data:
The majority of the personal data processed by us is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. LABS also processes personal data in order to comply with its legal obligations and/or based on your consent.
You should be aware that agreeing to any request for consent from our company is not a condition to enter any services agreement with us.
How LABS protects your personal data:
We process your personal data with great care and make sure it is always stored and transferred in the most secure way. We also make sure that only those LABS employees and contractors who needs it have an access to such data.
LABS takes appropriate commercially reasonable technical, physical and organizational measures to prevent unauthorized or unlawful processing of your personal data or accidental loss or destruction of your personal data.
Recipients and users of personal data:
We will only use your personal data for the purposes mentioned above, for performing our commercial contract and for legitimate purposes such as complying with our legal obligations. In this respect LABS may share your personal data with or transfer it to the following:
- Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
- Third parties whom we engage to assist in delivering the services to you;
- Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
- Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
- Our data storage providers;
- Banks, independent auditors and corporate service providers.
Your data may be processed through our secure computer network systems and accessed only by authorized users, employees and contractors within our company.
Marketing:
Based on your consent, we can send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you. We will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels.If you object to receiving marketing from us at any time, please contact us:
By email – [email protected]
By phone — +357 25 12 32 92
Transfer and processing of your personal data outside the European Union:
When sharing your personal data with third parties as set out in this Privacy Policy, it may be transferred outside the European Union. In these circumstances, your personal data will only be transferred on one of the following basis:
- the country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;
- you gave us a written consent to do it.
Depending on your needs LABS may transfer your personal data to some of the categories of data recipients mentioned above to the following countries outside the EU: Singapore, Hong Kong, China, Seychelles, British Virgin Islands, Belize, Panama, Russian Federation, Ukraine, Georgia, Kazakhstan, United Stated of America, United Arab Emirates, Canada, St. Kitts and Nevis, Gibraltar, Isle of Man, Isle of Jersey.
Your rights:
Under the GDPR you have the following rights:
- To obtain access to, and copies of, the personal data that we hold about you;
- To require that we cease processing your personal data if the processing is causing you damage or distress;
- To require us not to send you marketing communications;
- To require us to erase your personal data;
- To require us to restrict our data processing activities;
- To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
- To require us to correct the personal data we hold about you if it is incorrect.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights at www.dataprotection.gov.cy
If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact using the following:
By email – [email protected]
By phone — +357 25 12 32 92
If you are not satisfied by the way we are handling your personal data or have other unsatisfied complaints to LABS, you have a right to lodge a complaint to any supervisory authority of your chose. If you want to do it in Cyprus, please contact Cyprus authority by post at 1 Iasonos Str. 1082, Nicosia, Republic of Cyprus.
Retention:
LABS will process and store the relevant personal data for the duration of our services or for the duration of the business relationship. LABS may also store the data for as long as it is necessary or required in order to fulfill any legal, accounting, contractual or statutory obligations and, or for the establishment, exercise or defense of legal claims, and in general where it has a legitimate interest for doing so.
The personal data processed for marketing shall be kept with us until you notify us that you no longer wish for it to be used for such purpose.
Changes to this Policy:
LABS may update this Privacy Policy from time to time. If you gave us consent to provide you with our marketing materials or we have any contractual and/or legal obligations in front of you, we will inform you about such changes by sending you an e-mail.
