Privacy Statement

 

We are committed to managing and safeguarding your personal information in accordance with current legislation and best practice, Whenever you provide personal information, we will treat that information in accordance with this Privacy Notice.

 

By ‘Personal Data’, we refer to information collected or held by ATI Associates (referred to hereinafter as ATI) that identifies and relates to you as an individual including ‘Sensitive Personal Data’.

 

For the purpose of the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations, and particularly with article 7(1) of the Cypriot Processing of Personal Data (Protection of Individuals) Law 138(I)/2001 and its amendments, ATI will be the ‘data controller’ of all personal information.  ATI Associates determine the means and purpose of processing that data and is registered with  the Cypriot Commissioner of the Protection of Personal Data (the “Commissioner”), for this purpose.

 

ATI, when offering the service of Investment Advice, is obliged by Law to collect, to update and historically archive personal data (including Sensitive Personal Data) of its clients and potential clients and considers such information as being in our “Legitimate Interests”.

 

Examples of required personal data include;

• Names, addresses, telephone numbers, email addresses and other  contact details
• Family details and responsibilities
• Professional, academic, and other education related records, information on present past and intended business activities, financial resources and monetary commitments leading to an economic profile, proposed future financial planning

• Inheritance and disposal of assets.

 

We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected or reporting requirements, including the purposes of satisfying any potential legal or accounting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

We will only use your personal information if we have a relevant legal basis to do so.  This is usually in order to provide you with the contractual services you have requested from us, and to meet our legal reporting obligations towards the Authorities, or if you have provided us with adequate consent to process your information for other purposes.

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose that is compatible with the original intention.

We are committed to ensuring that your information is secure and we have procedures in place to try to prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect.

 

If we restructure our business or its assets, you have rights in relation to any Personal data that we hold about you.

 

If you wish to access your Personal Data you may make a formal subject access request by contacting ATI. Your rights include:

 

• To be informed about our processing of your personal data.
• The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed.
• The right to object to the processing of your personal data.*
• The right to restrict processing of your personal data.*
• The right to have your personal data erased.*
• The right to move, copy or transfer your personal data.*

 

NB : the exercise of the rights marked with * would technically conflict with the requirement under the prevailing Laws to maintain obligatory data of clients, and would presumably        lead to the compulsory annulment of the Business Agreement between ATI and a client.

 

A client should be aware that ATI may have another lawful reason to process the personal data in question even without your consent.

 

Please note that if you are not satisfied with the processing of your personal data as set out in this Privacy Notice, or consider that we have acted otherwise than in accordance with Data Protection Law please contact us at ati@cytanet.com.cy.

 

You have the right to make a referral or issue a complaint directly to the Commissioner for the data protection supervisory authority for Cyprus , commissioner@dataprotection.gov.cy although the ICO recommends that steps are taken to resolve the matter with us before involving them.