Updated May 21, 2018
Your privacy is important to us at Flexi Consultants (Cyprus) Limited and its affiliates ("Flexi Consultants" ). Flexi Consultants (Cyprus) Limited provides administrative services to clients and their companies and is the recipient of personal data (as that term is defined below) during the course of the provision of corporate and administrative services to you or to your companies. Flexi Consultants, in its capacity as administrative service provider authorized and supervised by the Cyprus Stock & Exchange Commission (“CYSEC”), is legally obliged to collect personal data from its clients which constitutes a ‘legal obligation’ as that term is defined under the GDPR legislation. As such, the collection of personal data by Flexi Consultants is not only permitted but also compulsory by law in Flexi Consultants’s regular course of business.
This policy may be amended at any time by posting a revised version at www.flexi-consultants.net . The revised version will be effective as of the time it is posted.
COLLECTION AND USE OF PERSONAL INFORMATION
Personal data means any information relating to an identified or identifiable natural person.
Flexi Consultants does not collect, and hence not process nor store, any personal data through its websites, including those of its affiliates, unless you decide to contact us by using the relevant Contact form of our Website(s). By filling in your personal and contact details in those specific contact forms available thereunder you consent to the collection and processing of such personal and contact details (personal data) by Flexi Consultants and its affiliates. In such an event, your personal data shall be collected and processed by Flexi Consultants and may be used by Flexi Consultants to contact you occasionally by sending you informational and explanatory notes and updates pertaining to legal and administrative developments that we may deem to be of interest to you.
You are not required to provide the personal information that Flexi Consultants requests, but if you chose not to do so, in many cases Flexi Consultants will not be able to provide you with its services or respond to any queries you may have and more importantly will not be able to enter into a contractual relationship with you.
In compliance with relevant EU and Cyprus law you have the following rights regarding the information you provide to Flexi Consultants. These include the right to:
(i) access any information you have provided to Flexi Consultants;
(ii) correct any information you have provided to Flexi Consultants;
(iii) delete any information you have provided to Flexi Consultants;
(iv) object to the use of information you have provided to Flexi Consultants; and
(v) have information you have provided to Flexi Consultants transferred to another company or entity.
Please note that if your information is required for Flexi Consultants to provide a service and you wish to restrict or delete that data, it may impact the ability of Flexi Consultants or its affiliates to provide such service(s). You will be advised of this outcome in the event that it arises.
PERSONAL INFORMATION FLEXI CONSULTANTS COLLECT
When you apply for any of our offered services, Flexi Consultants will collect a variety of information including, but not limited to: name, mailing address, phone number, email address, contact preferences, banking and financial information, government-issued identification documents, photo, or other form of documentation to prove your identity and/or residence (which may include an ID, number, or other similar unique identifier). Flexi Consultants may also have to collect certain information pertaining to your age or date of birth, marital status, ethnic origin, education or disciplinary history. This personal data and documents are necessary and legally mandatory upon Flexi Consultants in order for Flexi Consultants to provide the services it provides and to comply with the legal mandates imposed by our supervising body, namely CYSEC.
Some examples of the services Flexi Consultants provide where the collection of personal information occurs includes processing or the assistance in processing of:
• formation, incorporation, documentation, or other corporate services for a domestic or foreign corporate entity;
• opening of bank account(s) either in your name or under the trade name of your owned corporate entities;
• subscribing on your behalf or on the behalf of your corporate entities onto private, public or any other type of funds, including but not limited to investment funds, mutual funds and/or hedge funds;
• a billing account or address of record;
• registration, documentation, and other services related to registration of tangible or intangible assets belonging to you as a natural person or to any of your owned corporate entities;
• billing; and
• other activities in furtherance of or related to the above.
If you use and fill in the contact form on our website at http://flexi-consultants.net/c... (the “Contact Form”), then the following also applies:
Flexi Consultants will collect identifiable information of you, which constitutes personal data. Such personal data shall not be sold, transmitted to nor shared with any other company or individual but it may be used, provided you consent to it, for keeping you updated with developments and informative purposes in the areas of our business interests.
HOW FLEXI CONSULTANTS USES YOUR PERSONAL INFORMATION
Flexi Consultants may use your personal information, including date of birth, governmental identification documents, financial information (all constituting personal data) to assist with identification and to comply with domestic, EU and international laws, trade regulations, and other similar obligations.
Flexi Consultants may also use personal information to help create, develop, operate, deliver, and improve services as well as for money-laundering and terror-financing prevention and anti-fraud purposes.
Flexi Consultants may also use personal information for internal and administrative purposes such as auditing, data analysis, and research to improve the Flexi Consultants’s services and customer communications.
From time-to-time, Flexi Consultants may use your personal information to send important notices, such as regulatory and law-enforcement demands, requests and generally communications pertaining to your corporate entities maintained with or through Flexi Consultants and regarding current services and changes to our terms, conditions, and policies.
COOKIES AND OTHER TECHNOLOGIES
Flexi Consultants and its affiliates never use, process or transmit cookies.
DISCLOSURE TO THIRD PARTIES
Flexi Consultants will surely make certain personal information, constituting personal data, available to regulatory and law-enforcement authorities and offices, public bodies and authorities and strategic partners and professionals who are licensed and supervised by professional trade and/or regulatory associations and authorized domestic and foreign financial institutions that work with Flexi Consultants to provide its services, or that help the Flexi Consultants and its affiliates to enhance such services to customers.
For example, if you serve on the board of Directors of an entity formed by Flexi Consultants at your request, you authorize Flexi Consultants to share your information with the Registrar of Companies Office of Cyprus as well as other State or municipal authorities and public bodies.
Personal data will only be shared by Flexi Consultants to provide or improve services. Flexi Consultants and its affiliates shall never share, transmit nor sell personal data for marketing and/or promotional purposes.
DISCLOSURE TO SERVICE PROVIDERS
Flexi Consultants may share personal information with companies who provide legal, auditing, accounting and tax-planning advice and services. Immediately upon you becoming a customer of Flexi Consultants and/or of its affiliates for any service whatsoever offered thereby you shall be made explicitly aware of the names and details of the firms and professionals providing the aforementioned services and advice.
These companies and/or professionals are carefully selected to be strategic partners to Flexi Consultants not only for their impeccable knowledge and quality of service they provide but also because they are obligated to protect your personal data in a form and substance identical to that implemented by Flexi Consultants as they are subject to the same legal and regulatory rules promulgated by EU and domestic law.
DISCLOSURE TO OTHERS
It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within or outside Cyprus for Flexi Consultants to disclose your personal data. Flexi Consultants may also disclose information about you if Flexi Consultants determines that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary, appropriate or even prudent.
Flexi Consultants may also disclose your personal data if Flexi Consultants determines that disclosure is reasonably necessary to enforce the terms and conditions of our retainer or contract and protect our operation and interests. Additionally, in the event of a reorganization, merger, or sale, Flexi Consultants may transfer any and all personal information the Flexi Consultants collect to the relevant third party.
PROTECTION OF PERSONAL INFORMATION
When users send an email to Flexi Consultants, technology is used to prevent unauthorized third parties from viewing and downloading user information. Flexi Consultants processes personal information on servers in Cyprus and protects it by maintaining physical, electronic, and procedural safeguards such as: firewalls, secure sockets layer ("SSL") encryption, URL data encryption, file access privileges, physical server access controls, and authorizing access to personal information only for employees who require it to fulfill their job responsibilities. When your personal data is stored by Flexi Consultants, Flexi Consultants uses computer systems with limited access housed in facilities using physical security measures.
No data transmission over the Internet can be guaranteed to be 100% secure. As a result, Flexi Consultants cannot ensure or warrant the security of any information transmitted over the Internet. Flexi Consultants makes every attempt to ensure the security of all information collected.
INTEGRITY AND RETENTION OF PERSONAL INFORMATION
ACCESS TO PERSONAL INFORMATION
You can help ensure that your contact information and preferences are accurate, complete, and up-to-date by sending an email to firstname.lastname@example.org. For other personal information Flexi Consultants holds, Flexi Consultants will provide you with a copy for any purpose including to request that Flexi Consultants corrects the data if it is inaccurate or delete the data if Flexi Consultants are not required to retain it by law or for legitimate business purposes. Flexi Consultants may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Request for information, correction, or deletion can be made by emailing email@example.com.
CHILDREN AND EDUCATION
Flexi Consultants understands the importance of taking extra precautions to protect the privacy and safety of children using the Flexi Consultants’s services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to use the Flexi Consultants’s services, unless their parent provided verifiable consent.
If Flexi Consultants suspects that it has collected the personal data of a child under 13, or equivalent minimum age depending on the jurisdiction, without verifiable parental consent, Flexi Consultants will take steps to delete the personal data as soon as possible.
If at any time a parent needs to access, correct, or delete data associated with their child's information, they may email firstname.lastname@example.org.
THIRD PARTY SITES AND SERVICES
Flexi Consultants’s websites, applications, and services may contain links to third party websites, products, and services. Flexi Consultants services may also use or offer products or services from third parties. The inclusion of any link does not imply Flexi Consultants’s endorsement of any other company, its products, services, or privacy practices. Furthermore, Flexi Consultants and its affiliates are not responsible for personal information voluntarily disclosed by users to third parties that are contacted through links on any website.
Information collected by third parties, that may include such things as location data or contact details, is governed by their privacy practices. However, the strategic partners who are selected by Flexi Consultants to be its Service Providers (as that term has been defined above) constitute an endorsement by Flexi Consultants as to their privacy policies and subsequently their compliance with the current EU and national pertinent legislation. Flexi Consultants encourages you to learn about the privacy practices of those third parties.
Flexi Consultants, as a group of entities with global presence, has a number of affiliated legal entities in different jurisdictions that are responsible for the personal data which they collect and which is processed on their behalf. Such international third party service providers have been carefully assessed and Flexi Consultants ensures they implement the same level of protection with respect to personal data. Flexi Consultants employs appropriate technological and physical safeguards to keep information secure. However, please be aware that these safeguards may not meet the same standards as is required by the country in which you reside.
COMMITMENT TO YOUR PRIVACY
To ensure your personal data is secure, Flexi Consultants holds periodic informative sessions with its employees whose subject is on privacy and security guidelines whilst strictly enforces privacy safeguards amongst them.
When a privacy question or access/deletion request is received, the Flexi Consultants have a dedicated team, which endeavors to address the specific concern or query you are seeking to raise. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction or to the domestic regulator at http://www.dataprotection.gov.cy. Upon request, Flexi Consultants will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
 Flexi Consultants (Cyprus) Ltd. is an affiliate of Flexi (Nominees) Limited, Flexi (Trustees) Limited, Flexi (Secretarial) Limited, Flexi Overseas Limited, Flexi Executives Limited, Flexi Consultants Limited, Intermax Nominees Limited and Flexi Airwave Limited and the proprietors of the “www.flexi-consultants.net”, “www.flexi-airwave.com”,“www.flexi-overseas.com.”, www.flexi-executives.com, www.flexicompliancenews.com and “www.flexi-nominees.com”respectively.