Last updated: 23rd of May, 2018

This Data Privacy Policy applies to Personal Data processed by our Firm as a controller and processor, in accordance with the EU General Data Protection Regulation 2016/679 (GDPR) (as may be amended or supplemented from time to time) (hereinafter the “GDPR”) and in line with best practices applied.



Our Firm is committed to protecting your Personal Data and to achieving the best means of processing it in a fair and transparent manner.

We continuously reinforce our standards of technology, managerial measures and operational security, to ensure maximum protection of your Personal Data. Such measures include applying robust technical controls and procedures to restrict access as required as well as physical security measures by maintaining data at appropriately secured locations, and ensuring all our staff is educated and well-trained with regards to our privacy obligations, handling of Personal Data in strict confidence and applying appropriate measures when processing such data.



Personal Data means any information about an individual from which such individual may be identified.

Personal Data we process may include data grouped under the following indicative headings:

  • Identity Data: e.g. coloured passport copies / identity cards, first and middle name, surname, date of birth, gender, marital status, specimen signatures, etc.
  • Contact Data: e.g. company address, electronic mail, telephone numbers, residential address etc.
  • Profile / Financial Data: e.g. details on and information to substantiate ones source of wealth, size of wealth, profession, reference letters / recommendation letters, etc.
  • Transaction Data: e.g. details about payments to and from data subjects, businesses they are involved in, other details of the services we provide to data subjects such as records of meetings, etc.
  • Technical Data: e.g. internet protocol addresses (IP), time zone settings and location, cookies (Learn More).

We do not process Sensitive Personal Data including details on religion, sexual orientation, political opinions, etc.



In the provision of our services, our Firm processes Personal Data collected / received from a range of sources e.g. from:

  • data subjects, directly;
  • parties acting on the data subject’s behalf;
  • third parties e.g. agencies, credit institutions, etc.;
  • publicly available sources, such as registries.



Processing activities carried out by our Firm include:

  • collection,
  • recording,
  • organisation,
  • storage,
  • use,
  • disclosure by transmission or otherwise making available,
  • destruction, etc.,

    as may be required from time to time, for legitimate purposes and in the context of the carrying out of our professional activities / services.

We will only process Personal Data within the parameters permitted by law, which will most commonly include the following reasons:

  • to perform our contractual obligations / provide a service which our Firm has been engaged to carry out, e.g. asset management, investment advice, etc. 
  • for administration and operational purposes, including the provision of services by our Firm and our group of companies and affiliated companies; 
  • to comply with all legal and regulatory obligations we are subject to, including those required from time to time under the laws of the Republic of Cyprus, the European Union and other applicable laws, regulations and directives and obligatory guidelines set by our Supervisory Authority. Such legal and regulatory obligations may relate to the Prevention of Money Laundering, national and foreign security policy, prevention, investigation, detection or prosecution of fraud / criminal offences etc.; 
  • to perform a task carried out in the public interest;
  • to manage our relationship with the data subject, e.g. regarding the management of fees, notifying the subject of changes to our Data Privacy Policy, etc.;
  • on the basis of any other legitimate interest (including our legitimate interest and / or those of a third party).

As the protection of your Personal Data is of utmost importance for our Firm we make sure at all times to give careful consideration to and assess all legitimate interests that arise (including our legitimate interests, those of third parties and those of the data subject), against the data subject’s rights and potential impact thereon.

We may process Personal Data on more than one lawful ground, depending on the specific purpose for which we are using such data. Please contact us at for details about the specific legal ground(s) we are relying on in processing your Personal Data, should you wish to do so.



Personal Data shall be retained for:

  • as long as necessary to fulfil the purposes for which it was collected for;
  • any retention period that is required by a compelling legal obligation (e.g. by law, pursuant to litigation or investigation which might arise, etc.);
  • any retention period as per our Firm’s Retention Policy (details of which may be made available upon request).

In determining the appropriate retention period, our Firm gives careful consideration to applicable legal and regulatory requirements, the amount, nature and sensitivity of the data in question, potential risk of harm from unauthorised use or disclosure, and whether we could achieve the purposes at hand through other means.



In achieving the legitimate purposes for processing of Personal Data, we may have to share it with other parties which shall also act as processors or joint controllers of such Personal Data, e.g.: 

Internal Third Parties

  • other companies in our group of companies or to our affiliated companies.

External Third Parties

  • other service providers which our Firm cooperates with for the provision of further services / products, and of which our clients shall be informed of from time to time; 
  • credit institutions and other financial institutions;
  • third parties as and when explicitly requested / instructed by a data subject;   
  • Public / Semi-Public registries, maintained in the Republic of Cyprus or outside;
  • regulatory and / or supervisory and / or other competent authorities, when we are obliged to so do under law or court order;
  • other professionals such as legal advisors, auditors, insurers, etc., as may be necessary from time to time, in assisting them in adhering to their legal obligations, carrying out their duties and providing the services which they have been engaged to carry out.

We require all such parties to respect the security of your Personal Data and to treat it in accordance with the law.

Where such data is transferred to countries or territories outside the European Economic Area (not recognised by the European Commission as offering an adequate level of data protection), our Firm will ensure that appropriate data transfer mechanisms (as required) are put into place, such as EU Standard Contractual Clauses, to ensure protection of your Personal Data.



Your Rights 

Your rights are listed below and may be exercised to the extent permitted under the GDPR, in line and within the parameters of the legal and regulatory framework within which we - as a regulated Asset Management firm - operate, and in accordance with our Data Privacy Policy (as may be revised and communicated to you from time to time):

  • to request for data portability;
  • to request for access to your Personal Data, e.g. for updating or rectification purposes (where practical);
  • to request for clarifications as to the purposes for which your Personal Data is being processed and / or as to where it is being processed;
  • in some circumstances, to explicitly withdraw any consent provided to us, or limit such consent e.g. by requesting for the restriction of a specific processing of your Personal Data;
  • in some circumstance, to request for erasure of your Personal Data;
  • in some circumstances, to object to the processing of your Personal Data.

Your rights may be exercised by contacting:

Such requests shall not affect the lawfulness of any processing carried out before the exercise of your rights.

If, despite our commitment and continuous efforts to protect your data you feel that your data protection rights are not being adequately safeguarded, you may lodge an official complaint with the Data Protection Commissioner:


What We Need From You

It is important that all Personal Data we maintain on you remains accurate and current at all times. Please keep us informed if any of your Personal Data changes during your relationship with us.


Time Limit to Respond

We will try to respond to all legitimate requests within one month, depending on the complexity and number of requests.



Please be advised that the Data Privacy Policy shall be subject to periodic review; any modifications / changes, drafted in line with and within the parameters of the GDPR and other applicable laws, will be included on our Firm’s website:

Any modifications / changes and shall be effective as of the date of revision.

We thus encourage you to periodically review the Data Privacy Policy from time to time so as to remain informed about how we are protecting Personal Data.

Please note that the Data Privacy Policy supplements any other notices given to you from time to time, and is not intended to override them. This policy should always be read alongside other relevant Terms and Conditions such as Engagement Letters, Investment Services Agreement signed with our Firm, regulating services provided by us. 

This is the latest version of the Data Privacy Policy.

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