Alta Corporate Services Ltd is committed to protecting and securing your privacy.
This Statement explains how Alta Corporate Services Ltd collects, uses and discloses your personal data; and your rights in relation to your personal data.
Collection of your Personal Information
Alta Corporate Services Ltd collects and processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our services.
We will never collect any unnecessary personal data from you and will not process your information in any way, other than as specified in this statement.
Collection may take place either electronically, or via business meetings, or via forms you complete; and/or events and/or through the network of collaborators we have as well as from business relationships established between us and you.
Categories of Personal Information Collected
- Your name and contact information such as your home or business address, job title, email address and telephone number;
- Biographical information which may confirm your identity including your date of birth, 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;
- Reference letters, whether you hold/held a prominent public function (for PEPs), FATCA / CRS info, authentication data (e.g. signature)
- An understanding of your goals and objectives in procuring our services;
- Information about your employment, education, family or personal circumstances, and interests, where relevant; and
- Information to assess whether you may represent a politically exposed person or money laundering risk.
- Other third parties such as intermediaries who we introduce to you
Use of your Personal Information
Alta Corporate Services Ltd collects and processes your personal data to deliver the services you have requested and for reasons of compliance with applicable laws and regulations of Republic of Cyprus.
Alta Corporate Services Ltd does not sell, rent or lease its customer lists to third parties.
We 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, auditors, accountant.
Alta Corporate Services Ltd will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:
- conform to the edicts of the law or comply with legal process served on Alta Corporate Services Ltd;
- protect and defend the rights or property of Alta Corporate Services Ltd;
- act under exigent circumstances to protect the personal safety of users of Alta Corporate Services Ltd, or the public.
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 Statement, it may be transferred outside the European Union on one of the following:
- 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;
- The transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
- The recipient has entered into European Commission standard contractual clauses with us; or
- You have explicitly consented to transfer of data.
How long we keep your personal information
We retain personal data and records for as long as the business relationship lasts and for a period of at least five (5) years thereafter. We may maintain such records for as many years as possible, in order to comply with the Compliance Framework and applicable laws (including without limitation the data retention obligations inherent in Cyprus tax laws).
We have put in place appropriate technical and organisational measures including physical, electronic and procedural measures to protect personal data from loss, misuse, alteration or destruction.
What are your data protection rights?
The following are the rights you have pursuant to the provisions of the GDPR and the applicable local legislation (as amended from time to time) in relation to the data protection:-
- Request access to your personal data (commonly known as a “data subject access request”).
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. In such a case, your data will be stored but not processed until expiration of the retention obligation.
- Subject to the legal basis on which the processing activity is based, you may object to processing of your personal data. Please note that in some cases, we may have compelling legitimate grounds to process your information which we need to comply with.
- Request restriction of processing of your personal data (a) if it is not accurate;(b) where processing may be unlawful but you do not want us to erase your data; (c) where you need us to hold the data even if we no longer require it; or (d) where you may have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party.
- In case the processing of the data is performed subject to your consent, you may withdraw consent at any time where we are relying on consent to process your personal data. However, we note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will of course advise you if this is the case at the time you withdraw your consent.
- Note that we may charge you with an administrative fee, in cases where requests are deemed manifestly unfounded or excessive, in particular because of their repetitive character.
Changes to this Statement
Alta Corporate Services Ltd will occasionally update this Statement of Privacy to reflect company and customer feedback. Alta Corporate Services Ltd encourages you to periodically review this Statement to be informed of how Alta Corporate Services Ltd is protecting your information.
Alta Corporate Services Ltd welcomes your comments regarding this Statement of Privacy. If you believe that Alta Corporate Services Ltd has not adhered to this Statement, and/or you have any questions or queries with respect to your personal data, please contact Alta Corporate Services Ltd at firstname.lastname@example.org.
We will use commercially reasonable efforts to promptly determine and remedy the problem.