PRIVACY NOTICE

PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR) which is effective as from 25th May 2018.

ABOUT US
Vaulterra Trustees and Corporate Limited (the ‘Company’) is a limited liability company incorporated in Cyprus, with registration number HE327307. The company offers a wide spectrum of company administration services and since 2014 is regulated under the Cyprus Securities and Exchange Commission for the management or directing of trusts and the undertaking or provision of the service of managing companies under license number 59/196. The registered office of the Company is at 8 Stasinou Avenue, Photos Photiades Business Centre, Office 402, 1060, Nicosia, Cyprus

HOW WE MAY COLLECT YOUR PERSONAL DATA
We may collect personal information as part of our engagement for the provision of corporate and general administration services with our clients. Also personal information may be submitted through the use of our website.
In some circumstances, we may collect personal data about you from third parties – for example, we may collect personal data from your organisation, other organisations with which you have dealings including Third Party Entities, government agencies, a credit reporting agency, an information or service provider or from a publicly available record.

USE OF COOKIES
The main purpose of a cookie is to identify users and possibly prepare customized web pages for them. When you enter our website, you may be asked to fill out a form providing such information as your name, address and age. This information is packaged into a cookie and sent to your browser which stores it for later use. The next time you visit our website, your browser will send the cookie to the server and the server can use this information to present you with custom pages.

Vaulterra Trustees and Corporate Limited may use cookies for the purposes of analytics of our web site such as number of visitors and pages visited. In the case that you would prefer to block, restrict or delete cookies from Vaulterra Trustees and Corporate Limited or any web site you can use your browser to do so. Depending on your web browser you can refer to the ‘Help’ menu to identify how to manipulate the cookie preferences.

In case you would like to learn more on cookies you can refer to aboutcookies.org

THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal information could be any information that could identify an individual such as name, passport or ID number, age, date of birth, phone number or postal address. Other information may also be requested such as occupation, marital status and children

The information we may collect and hold about you may include the following:

Contact information: Information such as your name, job title, postal address, home address, business address, telephone number, mobile number, fax number and email address.

Business details: Business information which we necessarily process as part of our instructions or assignments we are involved in or otherwise provided by you voluntarily.

Correspondence: Details of any correspondence with you, including but not limited to details of contact we have had with you in relation to the provision, or the proposed provision, of our services, details of any services you have received from us, and our correspondence and communication with you.

Compliance details: Information we are legally required to collect for compliance purposes, such as ‘know your client’ information, details relevant to international sanctions and restrictive measures and information about relevant and significant litigation, which may impact our ability to act.

Publicly available information: Information collected from publicly available resources, including but not limited to information collected from databases we use to carry out compliance checks or credit rating agencies.

Statutory Information: Information about you on account of an interest or office you may hold in or certain relationships you may have with a corporate entity, partnership, trust or other vehicle to which we provide services (each such entity, a Third Party Entity).

HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
The personal information collected is used by Vaulterra Trustees and Corporate Limited to comply with legal and compliance requirements as part of our engagement and acceptance of any client for the provision of our services. You can request to view, amend the details, object to processing or withdraw any consent we may hold on processing information about you. You can contact us at info@vaulterracorp.com

It may further be the case that personal information we hold about you is shared with third party service providers as part of our obligations to fulfil the terms of engagement of our services. In addition, from time to time and in order to provide services to you, Vaulterra Trustees and Corporate Limited may need to transfer your personal information [outside the EEA] to countries that may not provide a level of protection of personal information that may be regarded as equivalent to that afforded under the European data protection legislation. Whenever your personal information is transferred internationally, we will take appropriate steps to ensure its security and confidentiality in accordance with applicable data protection law. Also, in the case that it may be required by law or the public authorities.

DATA RETENTION
Personal information will only be kept by the Company for the period as required by the law and in accordance with our data retention policies.

CHANGE OF PURPOSE
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

REFUSAL TO SHARE YOUR PERSONAL DATA WITH US
There are certain cases where we will unfortunately be unable to act without receiving such data, for example where we need to carry out legally required compliance screening or require such data to process your instructions or orders, or otherwise to provide you with our online services or communications.

Where it is not possible for us to provide you with what you request without the relevant personal data, we will let you know accordingly.

PERSONAL DATA WE RECEIVE FROM YOU ABOUT OTHER PEOPLE
Where you provide us with the personal data of other people, such as your employees, directors of your companies, or other persons you may have dealings with, you must ensure that you are entitled to disclose that personal data to us and furthermore that, without being required to take further steps, we can collect, use and disclose that data in the manner described in this policy. More specifically, you must ensure that the individual whose personal data you are sharing with us is aware of the matters discussed in this Privacy Notice, as these are relevant to that individual, including our identity, how to get in touch with us, the purposes for which we collect data, our disclosure practices, and the rights of the individual in relation to our holding of the data.

YOUR RIGHTS IN CONNECTION WITH PERSONAL DATA
Our privacy policy may be amended or revised from time to time depending on amendments to our internal policies or to the Data Protection Regulations.
In the case we receive notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

CHANGES TO THE PRIVACY POLICY
Any changes we may make to our privacy notice in the future will be updated on our website or sent to you by email.

This privacy notice was last updated on 24 May 2018.

CONTACT US
In case of any concerns on the use, retention, safety or withdrawal of your consent to the use of your personal information you can contact us at info@vaulterracorp.com or (+357) 22889399.