Privacy Policy

Exectus Ltd, a limited liability company incorporated and registered in Cyprus with registered office at 6A Sarpidonos, 2326 Lakatamia, Nicosia, Cyprus and company number HE 389667 (“we”, “us”, “our” “the firm”) is an accounting/audit firm regulated by The Institute of Certified Public Accountants of Cyprus.

Details of how to contact us can be found below in the section titled “Who should you contact with questions?”

We generally collect data from you directly, but we may also collect data from third parties such as:

• Our clients, including if our client is your employer.
• Our partners, such as when we host a joint event that you choose to attend.
• Our professional advisers, your professional advisers and other service providers.
• Associates of yours, including family members, colleagues and your connections.
• Publically available sources, such as social media.
• Third party data providers and marketing companies.
• Your agents and representatives (such as your power of attorney).

The data we collect and for what purpose will depend on who you are and the nature of the relationship that you have with us. This data may include:

• Basic contact information.
• Marketing preferences.
• Records of your use of our website.
• Information relevant to your role as a trustee or beneficiary.
• Records of communications that you have with us.
• Other information that you provide to us voluntarily.

Details of how to contact us can be found below in the section titled “Who should you contact with questions?”

Throughout the duration of our provision of services to you, we may use data about you for the following purposes:

• To communicate with you, such as in the course of a commercial relationship between us and your employer.
• To send you marketing communications, such as via email or post.
• To create and manage records of your involvement with us.
• To comply with our legal and regulatory obligations.
• To share your data with relevant third parties.
• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

The legal basis for our use of data about you is one of the following, the processing of your data is necessary for:

• The performance of a contract to which you are a party;
• Compliance with a legal obligation to which we are subject; or
• A legitimate business interest that is not overridden by your interests, rights and freedoms which require protection.
• Where none of the above conditions apply, we will ask for your consent to process the data.

We may share data about you with:

• Third parties who provide us with products or services. A full list of third party providers is available on request.
• Other third parties, where required or permitted by law.

You may have the following rights in respect of data about you that we hold:

• Request us to give you access to it;
• Request us to rectify it, update it, or erase it;
• Request us to restrict our using it, in certain circumstances;
• Object to our using it, in certain circumstances;
• Withdraw your consent to our using it;
• Data portability, in certain circumstances;
• Opt out from our using it for direct marketing; and
• Lodge a complaint with the supervisory authority in your country (if there is one).

You are able to exercise these rights by contacting us using the details set out below.

If you have any questions, or wish to exercise any of the rights detailed above, please contact us at [email protected] .

You have a right to contact your local supervisory authority (for Cyprus the data protection authority at [email protected]) with any questions or concerns. If we or they cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.

Basic contact information
This may include your name, email address, telephone number and postal address. If you are an officer or employee of a company, then we may also record details of your role and the identity of your employer.

Marketing preferences
If you receive marketing communications from us (eg by email or post), then we will hold your marketing preferences on record which you may update at any time.

Records of your use of our website
If you visit our website, then we will install certain cookies on to the device that you are using. Further detail about how we use cookies is set out in our cookie policy.

Information relevant to your role as a trustee or beneficiary
We may need to collect information about any trust that you are a trustee or beneficiary of. This may include details of your financial circumstances, the benefit that you may be entitled to and other information such as trust deeds and trust minutes.

Records of communications that you have with us
If you contact us or we contact you for whatever reason (eg by email or letter), then we will retain records of such correspondence.

Other information that you provide to us voluntarily
This could include details such as dietary requirements.

Further information on the purpose(s), methods of collection and legal basis for processing your data

The purposes for which we use your data, and the corresponding methods of collection and legal basis for its use, are described below:

To communicate with you

Purpose

In the course of our relationship with you (or your employer) we may need to communicate with you by email, phone, post or in person.

This may be, for instance, in relation to the service you are providing or receiving from us.

To respond to an enquiry submitted on our website, at one of our local offices or via phone, email, post and SMS.

Method of collection

We will generally collect contact details directly from you or (where applicable) your employer. This may be, for instance, you sending us an email or providing one of our staff members with a business card.

Legal basis

We have a legitimate business interest to contact you in the course of any commercial business relationship.

To send you marketing communications

Purpose

In accordance with your preferences, we may send you marketing materials and communications via email, post or telephone.

You may also be contacted from time to time by our partners and other employees about potential meetings and events.

Method of collection

We will generally collect contact details directly from you or (where applicable) your employer. This may be, for instance, you sending us an email or providing one of our staff members with a business card.

Legal basis

It is our legitimate business interest to send you marketing materials.

Where we have obtained your consent to send marketing materials and communications then we instead rely on consent as the legal basis.

To create and manage records

Purpose

We will keep records of the data we collect about you in accordance with our data retention policy (see the section How long will data about you be kept?).

This will include, for instance, records of written communications between you and us.

Method of collection

The data will generally be collected directly from you or your employer, although the means of collection will depend on the type of data that is being recorded.

Legal basis

We have a legitimate business interest to retain and manage records for as long as is necessary to fulfil the other purposes outlined in this notice.

To comply with our legal and regulatory obligations

Purpose

To defend our legal rights in the event of a claim or dispute.

Method of collection

The data will generally be collected directly from you or your employer, although the means of collection will depend on the type of data that is being recorded.

Legal basis

We have a legitimate business interest to use your data where necessary to defend any claims that are made against us.

To share data with relevant third parties

Purpose

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

Method of collection

We will generally collect contact details directly from you or (where applicable) your employer. This may be, for instance, you sending us an email or providing one of our staff members with a business card.

Legal basis

It is our legitimate business interest to share your data with third parties who provide us with services relevant to our provision of the website and other services. Whenever we share your data with third parties then we look to put in place contractual protections to govern how your data is used.

Where we do not base our use of data about you on one of the above legal bases, we will ask for your consent before we process the data (these cases will be clear from the context). We may from time to time ask for your explicit consent to process special categories of your data (such as racial or ethnic origin or health and medical information). In these circumstances we will provide specific information to you about both the relevant processing activities and your rights in relation to them.

In some instances, we may use data about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.

Further information on where data about you might be sent

When using data as described in this notice, it may be transferred either within or outside the country or territory where it was collected, including to a country, territory or international organisation that may not have the same data protection standards.

In all cases, the transfer will be on the basis of a European Commission adequacy decision or we will implement adequate measures, for example the EU Model Contracts, including appropriate security measures, for the protection of personal data in those countries, territories or international organisations in accordance with applicable data protection laws, or we will use a supplier who has certified to the US Privacy Shield Framework.

Further information on your rights in respect of the data we hold about you

In respect of the data we hold about you, you will have the rights set out below (note: certain legal limits apply to all these rights):

To request that we give you access to your data

This is confirmation of:

• Whether or not we process data about you;
• Our name and contact details;
• The purpose of the processing;
• The categories of data concerned;
• The categories of persons with whom we share the data and, where any person is outside the EU and does not benefit from a European Commission adequacy decision, the appropriate safeguards for protecting the data;
• (If we have it) the source of the data, if we did not collect it from you;
• (To the extent we do any, which will have been brought to your attention) the existence of automated decision-making, including profiling, that produces legal effects concerning you, or significantly affects you in a similar way, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; and
• The criteria for determining the period for which we will store the data.

On your request we will provide you with a copy of the data we hold.

To withdraw your consent to our using it

This right applies to any data which we have collected and process based on your consent.

You have the right at any time to withdraw the consent you have provided to us.

To request that we rectify or update your data

This applies if the data we hold is inaccurate or incomplete.

To request that we erase your data

This applies if:

• The data we hold is no longer necessary in relation to the purposes for which we use it;
• We use the data on the basis of your consent and you withdraw your consent (in this case, we will remember not to contact you again, unless you tell us you want us to delete all data about you in which case we will respect your wishes);
• We use the data on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it;
• The data was unlawfully obtained or used; or
• To comply with a legal obligation.

To request that we restrict our processing of your data

This right applies, temporarily while we look into your case, if you:

• Contest the accuracy of the data we use; or
• Have objected to our using the data on the basis of legitimate interest.
• (If you make use of your right in these cases, we will tell you before we use the data again).
• This right applies also if:
• Our use is unlawful and you oppose the erasure of the data; or
• We no longer need the data, but you require it to establish a legal case.

To object to our processing of your data

You have two rights here:

1. If we use data about you for direct marketing: you can “opt out” (without the need to justify your decision) and we will comply with your request; and
2. If we use the data about you on the basis of legitimate interest for purposes other than direct marketing, you can object to our using it for those purposes, giving an explanation of your particular situation, and we will consider your objection.

To portability of your data

This right applies:

1. To data that you have provided to us; and
2. If we use that data on the basis either of your consent, or on the basis of discharging our contractual obligations to you.

If both (1) and (2) apply, you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else.

To lodge a complaint with the supervisory authority in your country

Each European Union country must provide for a regulator for this purpose.

You can find their contact details here.