WHAT DATA DO WE HOLD:
We process data in the context of providing legal and other services to clients. The categories of data we collect and process, according to the particulars of each case include: Contact details (including names, surnames, postal addresses, email addresses, telephone and fax numbers numbers).
Information required by Vergina Trust Limited to meet legal and regulatory requirements, in particular in respect of anti-money laundering legislation, including but not limited to information on source of funds and source of wealth, Marital status, Tax Residency, Employment information, Identification documentation, Proof of Residence, whether you are part of any criminal proceedings, Whether you have dual nationality, whether you are a Politically Exposed Person, whether you are a US National, whether you hold a US Green card etc. Information provided in the course of the provision of legal, corporate, fiduciary, financial, banking, accounting, payroll, tax, administrative, advisory (non-exhaustive list) (for example, information on professional relationships and background, financial wealth and assets held, transactions entered into, tax status, disputes and court proceedings engaged in). Financial information, such as payment related information, meetings attended and visits to our offices; any other information you may provide to Vergina Trust Limited for the enablement of services as requested by you.
SPECIAL CATEGORY DATA:
In certain cases, the personal data that we process may include "Special Category Data" (includes information on a person's race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data processed for the purpose of uniquely identifying a natural person, health data, data on a person's sex life or sexual orientation or data relating to a person's criminal record or alleged criminal activity). In such instances, legal bases for processing that data may include explicit consent (where the Special Category Data has been provided to us by the data subject for any of the above-listed purposes) or the processing is being necessary for compliance with a legal obligation or for the purposes of legal proceedings or legal advice.
WHY DO WE NEED THIS DATA?
Vergina Trust Limited ensures that the data collected and processed is relevant to one or moreprocessing activities and that we do not collect nor process more or less data than what is reasonably required for achieving the purpose of each processing activity.
PURPOSES OF PROCESSING:
The sources of data may include clients, intermediaries, other data processors, other data controllers, data subjects directly, third parties connected to the data subject,open-source material, client representatives, Banks , Credit institutions, Administrative Service Providers, Lawyers, Auditors, Accountants, public authorities, any legal entity and/or third party individual who might introduce clients ( Individual and corporate) to us, Companies who Process Payments, The Department of Registrar of Companies and Official Receiver, The Land Register, The Bankruptcy Archive, the press, media, and the Internet.
Reasonable endeavours are made to ensure that data is only accessible by those with a need for access to fulfil the purposes set out above. Requests for access to be restricted in any particular manner should be made to email@example.com and where possible with reference to legal and regulatory obligations, actioned.
The following is a list of potential recipients of data (in each case including employees, directors and officers): Employees of Vergina Trust Limited who received the appropriate training with regard to the GDPR and have signed Vergina Trust Limited Confidentiality and Non-Disclosure Agreement.Other service providers ( Legal, Administrative, Governance or otherwise, including any bank or financial institution, audit firm, accountant firm and/or related individuals in relation to the service for which Vergina Trust Limited has been engaged) where disclosure to that provider of services is considered necessary to fulfil the purposes set out above as well as Courts or Tribunals, third parties with whom Vergina Trust Limited elaborates for the hosting of events, law enforcement agencies where considered necessary for Vergina Trust Limited to fulfil legal obligations applicable to it, Regulators or other governmental or supervisory bodies with a legal right to the material or a legitimate interest in any material, any registrar of a public register where the data is to be included in a public registry.
Unless expressly declared in this Privacy Notice or with the prior consent of the individual, personal data collected from an individual will not be disclosed to any third party other than the above-named parties.
Where Vergina Trust Limited is entering into an engagement with a third party pursuant to which data may be processed by that third party, Vergina Trust Limited will seek to enter into an agreement with that third party setting out the respective obligations of each party and it will seek to be reasonably satisfied that the third party has measures in place equal to those of Vergina Trust Limited to protect data against unauthorised or accidental use, access, disclosure, damage, loss or destruction.In the event that any such third party is outside of the European Union and where the data being transferred would include personal data which would be protected under applicable Data Protection regulation Vergina Trust Limited will ensure that it meets the relevant requirements of that Data Protection regulation prior to carrying out any such transfer. This may include only transferring the data where Vergina Trust Limited satisfied that:
- The non-European Union country has Data Protection laws similar to the laws in the European Union;
- The recipient has agreed through contract to protect the information in the same Data Protection standards as the European Union;
- We have obtained consent from relevant data subjects to the transfer;
DATA SUBJECTS RIGHTS:
Data subjects in the European Union (or any jurisdiction with equivalent legislation to the European Union General Data Protection Regulation) have certain rights in respect of their personal data. Any such data subject wishing to exercise any rights under applicable data protection laws (including the right to withdraw any consent to processing previously given (shall not affect the lawfulness of processing based on the consent before it was withdrawn or revoked) , access to data; or to have data corrected, updated, rectified or erased; or for access to data to be restricted or provided to any third partyor to object to any particular processingor to lodge a complaint with the relevant supervisory authorityor the right to data portability) should send the request in the first instance to firstname.lastname@example.org. In response to such requests, Vergina Trust Limited reserves the right to require the individual making the request to provide certain details about himself/herself so that Vegina Trust Limited can validate that the individual is indeed whom the data refers to. Vergina Trust Limited is required to respond to the request of the individual without delay and latest within one month of receipt of the request and it will ensure to do so wherever possible. Vergina Trust Limited reserves the right to charge a reasonable fee to cover any expenses that may arise from the request.In any case in which a data subject chooses not to provide any personal data, or where any of the rights set out above are exercised to limit the processing of personal data, Vergina Trust Limited may be unable to provide relevant services, or there may be restrictions on the services which can be provided.
RETENTION OF DATA:
Vergina Trust Limited retains personal data in accordance with its Data Retention Policy. Any personal data provided to Vergina Trust Limited is retained according to such policy, to fulfil the purposes for which the data was collected. Once the business relationship has been terminated, we are obliged under the relevant AML Laws and Regulations to maintain these records consisting of personal data, for a period of minimum 5 years.Any requests for further information in relation to the continued processing of specific data and requests for destruction of data should be made to email@example.com
PERSONAL DATA IN LEGAL PROCEEDINGS:
If it becomes necessary that Vergina Trust Limited is obliged to take action against you for any reason whatsoever, including but not limited to recovering from you any money you owe to Vergina Trust Limited, you expressly agree that the personal data provided by you can be relied upon in identifying and taking legal action against you.
CHANGES TO THIS PRIVACY NOTICE:
Vergina Trust Limited keeps this Privacy Notice under review in order to ensure that it is in line with any changes to the laws relating to privacy and personal data. Any updates will appear on Vergina's Trust Limited website at www.verginatrust.com
This Privacy Notice was last updated on 25 May 2018.
All enquiries in respect of this Privacy Notice should be directed to the designated email address firstname.lastname@example.org or by post at: Arch. Makariou III 67 & 2B Orfeos Street, 1st Floor, Office 104, 1070 Nicosia
Note that The General Data Protection Regulation (EU) 2016/679 shall apply from 25 May 2018. Until then the Processing of Personal Data (Protection of Individuals) Laws 2001 until 2012 remain in force.
Additional information about your rights under the data protection regulation you may find on the link below: