1. Privacy Policy for website
  2. Website policy

 

Introduction

Collected data and information

  • Information we collect
  • Other parties
  • Data collection
  • Data controller

Personal data: sharing and processing

Security process

  • Information security

Emergency policy

Amendments to Privacy Policy

 

Privacy Policy

Highworth (Cyprus) Limited is a Cyprus incorporated company, licenced under the Institute of Certified Public Accountants of Cyprus (hereinafter referred as ‘HWCY’). This Privacy Policy wishes to inform all HWCY clients and related parties regarding the policies adopted to ensure data protection based on the recent EU Regulation on the General Data Protection Regulation (‘GDPR’) 2016/679 which was voted on the 27th April 2016, fully enforced on 25th May 2018.

This publication has been carefully prepared to indicate the purpose of this Privacy Policy and enable HWCY to ensure its clients and all related parties that HWCY shall handle the enforcement of the new Regulation with full responsibility and commitment, ensuring safe protection of personal information and protection of all personal fundamental rights. This publication acts solely as guidance and is not to be considered binding or assume any responsibility though to cover all and/or specific situations requesting specific treatment. In such occasions, we highly recommend contacting HWCY directly for more targeted guidance.

 

  • Collected data and information

HWCY is a service provider also under obligation to applying and implementing numerous other Directives, Regulations, national and international legislation. A significant role in our business is the implementation of Anti-Money Laundering Directive, according to which HWCY is required to collect and keep the Know-Your-Client, Due diligence documentation and any other personal data required for transaction monitoring and identification purposes.

The above documents/data are kept for period of at least five (5) years, which is calculated after the execution of the transactions or the termination of the business relationship. The documents/data relevant to ongoing investigations are kept until MOKAS confirms that the investigation has been completed and the case has been closed.

For new prospective clients and all third parties related to a transaction of a client, background checks and collection of personal information are required prior entering into a contractual engagement or signing any documentation so as to enable us to comply with our legitimate obligations towards our Regulator and ensuring personal data protection under the given circumstances.

 

  • Information we collect

Any information about an individual, constitutes personal information and data collected for identification purposes. For this reason, prior concluding any engagement agreement or proceed with execution of any documentation, we may request to collect identification and contact data of an individual i.e. passport copy and proof of address. Banking details may also be required to also include more personal information e.g. authentication data i.e. signature, marital status, insurance information, tax identification number, residency, employment position, education background i.e. CV, as well as financial information to include nature of transactions, source of income, size of wealth etc.

 

  • Other parties

Any other personal data and documentation that needs to be collected and kept for other parties other than the above, will be communicated specifically to the Client and the storage period will be separately circulated.

* It is also important to note that the expired documents i.e. expired passports, utilities more than 6 months old, will be destroyed as soon as the updated documents are obtained.

 

  • Data Collection

Collection of data is a significant aspect of our scope of services rendered to our Clients.

 

  • Data Controller

HWCY is deemed to be considered the data controller for all documents, information and data collected with regards to the purpose of services provided and upon the acceptance of a Client. Our offices are located at 20 Omirou street, 3rd Floor, Office 301, 1097 Nicosia, Cyprus.

For greater ease of things, we have appointed a Data Protection Officer who is responsible to manage all data and information related to privacy matters. Any specific requests or inquiries, please contact HWCY at info@highworth.co or by telephone on +357 22 77 78 84.

 

  • Personal data: sharing and processing

HWCY is a service provider under obligation to fulfil and comply with numerous requirements. Legal requirements for combating money laundering and financing international terrorism, FATCA and CRS obligations as well as tax reporting requirements found under both national and European legislation, not limited to other national reporting obligations, constitute the milestones for determining the level of personal data required for a service to be offered. Such laws and regulations applicable, indicate mostly the level of personal data required to be processed for compliance monitoring. This may result to the sharing and processing of personal information within more than one department of HWCY.

Furthermore, statutory requirements found under Cyprus Banking laws, national tax laws and in addition to the obligations provided by the national supervisory authorities they all add up to the obligations and requirements to be met on behalf of the service providers. Based on these obligations, data and information data sharing and processing may include the relevant tax authorities, accountants and auditors, depending on the nature of the client request and service to be provided.

It is important to note that personal information and data collection are not to be shared with any unrelated third parties besides in those circumstances whereby there is a lawful obligation to do so and/or to enable us to fulfil our servicing obligations outsourced. External agents, partners and associates of HWCY as well as other interrelated third parties for the completion of the service to be provided are entering into an NDA agreement with HWCY and the personal data collected are also subject under their GDPR policy. All our third-party agents and associates are restricted from using the personal information and data collected for their personal purpose but are under the obligation to act upon the provision of our instructions, unless there is a legislative breach permitting otherwise.

Should a service required involves processing to any third party falling outside the indicated parties/authorities as mentioned above, the appropriate consent from the client shall be sought. Provision of such consent may no longer fall under our responsibility, but it shall constitute lawfulness by itself. Revocation of such processing lays with the client at any given time though. Any responsibility prior revocation escapes our care.

 

  • Security process

All data and information held under HWCY’s responsibility, is ensured that they shall not be given, granted, disclosed, dispatched, copied, mailed or electronically send to any parties, individuals, organisations, institutions for any other purpose besides the scope of services provided and obligations carried under AML, or national legislation which prevail over GPDR, without your approval or additional written consent.

Should we consider necessary, contact and/or communication shall be done via phone or email for further briefing on this matter.

 

  • Information security

We, at HWCY wish to ensure that all data and information collected receive strict protection. For this reason, we have reinforced our technological security via the use of additional electronic tools and platforms available well as operational security to safeguard sensitive information with restricted access to the non-interested or non-related parties within our company.

 

  • Emergency policy

In the case of a potential breach in safeguarding the data and information collected due to external factors i.e. hacker attach or data leakage, HWCY shall take immediate actions to inform all its clients. The Clients need to be contacted and informed within 24 hours from the time the breach was identified and report such breach to the relevant Supervisory Authority in Cyprus in the next 72 hours.

 

  • Amendments to privacy notice

HWCY reserves all rights for further amendments to be made occasionally regarding the present Privacy Policy based on the legal framework implemented therefore, any adjustable changes shall be further communicated.

Respective notices shall be posted and updated on our website accordingly with immediate effect or as it may be stated therein. It would be highly recommended to check on a regular basis whether any changes have been made for your greater convenience.

 

Website policy

 

Introduction

Consent to processing

Personal data collected

  • Technical information
  • Retention of Information
  • Information Security
  • Amendments to privacy notice

Website cookies

 

Website policy

Highworth (Cyprus) Limited is a Cyprus incorporated company, licenced under the Institute of Certified Public Accountants of Cyprus (hereinafter referred as ‘HWCY’). This Privacy Policy wishes to inform all HWCY clients and related parties regarding the policies adopted to ensure data protection based on the recent EU Regulation on the General Data Protection Regulation (‘GDPR’) 2016/679 which was voted on the 27th April 2016, fully enforced on 25th May 2018.

This publication has been carefully prepared to indicate the purpose of this Privacy Policy and enable HWCY to ensure its clients and all related parties that HWCY shall handle the enforcement of the new Regulation with full responsibility and commitment, ensuring safe protection of personal information and protection of all personal fundamental rights. This publication acts solely as guidance and is not to be considered binding or assume any responsibility though to cover all and/or specific situations requesting specific treatment. In such occasions, we highly recommend contacting HWCY directly for more targeted guidance.

 

  • Consent to processing

Our website is designed in such way providing all users the option to opt out or request for their consent to continue their experience on our website. Cookies notification for improving this experience appears and depends clearly on the user to choose further how to proceed.

By accepting our notifications, this automatically constitutes that the user has clearly read and understood the terms and conditions and has granted full consent to any policies adopted.

It is our obligation to encourage our visitors to check the privacy policy enclosed and the website’s terms and conditions as well as any amendments adopted from time to time.

 

  • Personal data collected

It is worth mentioning that the website www.highworth.co does not require any sort of registration to obtain access to any public information and/or data shared on the website. Visitors in this way, diminish the obligation to provide their personal details i.e. name, job title, telephone number and contact details, to secure access in return.

Please note that the above policy, ceases application once the visitor decides to take the opportunity to contact HWCY via email or telephone number as personal details become immediately known to the company and may be collected and processed within the company for better servicing purposes.

 

  • Technical information

This use of this website is resulting to the collection of technical information. Information such as IP (Internet Protocol) address, pages you visit on the web as well as on www.highworth.co, information as to which browser was used to access the website etc are some of the information to be retrieved and obtained.

In addition to the above, visitors need to take into consideration that this website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses “cookies”, which are text files placed on the visitor’s computer, to help the website analyse how users use the site.

The information generated by the cookie about the visitor’s use of the website (including IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating the visitor’s use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate the visitor’s IP address with any other data held by Google. Visitors may refuse the use of cookies by selecting the appropriate settings on their browser, however please note that this may result to the inability to use the full functionality of this website. By using this website, the visitors consent to the processing of personal data by Google in the manner and for the purposes set out above.

 

  • Retention of information

Data and information provided by the visitor as per 2.0., shall be kept by HWCY for the period required to fulfil the relevant request and in accordance with any laws applicable. Removal of data and/or information are subject to the terms and conditions found under our Privacy Policy.

 

  • Information security

We, at HWCY wish to ensure that all data and information collected receive strict protection. For this reason, we have reinforced our technological security via the use of additional electronic tools and platforms available well as operational security to safeguard sensitive information with restricted access to the non-interested or non-related parties within our company.

 

  • Amendments to privacy notice

HWCY reserves all rights for further amendments to be made occasionally regarding the present Website Policy based on the legal framework implemented therefore, any adjustable changes shall be further communicated.

Respective notices shall be posted and updated on our website accordingly with immediate effect or as it may be stated therein. It would be highly recommended to check on a regular basis whether any changes have been made for your greater convenience.

 

  • Website cookies

Cookies are also known as browser cookies or tracking cookies which, in reality, are small commonly encrypted text files, located in browser directories. For matters of understanding a web browser could be one of the following well-known browsers widely used i.e. Internet Explorer, Google Chrome, Mozilla Firefox. Cookies are mainly used to assist users navigate their websites efficiently and perform various functions. Due to their core role of enhancing/enabling usability or site processes, disabling cookies may prevent users from using certain websites.

Cookies are downloaded on a visitor’s computer when a visitor’s browser loads a certain website. The website sends information to the browser which then creates a text file. Every time the visitor revisits the same website, the browser retrieves and sends this file to the website’s server. This means that it automatically recognises the visitor and remembers personalised details and preferences.

Computer Cookies are created not just by the website the visitor is browsing but also by other websites that run ads, widgets, or other elements on the page being loaded. These cookies regulate how the ads appear or how the widgets and other elements function on the page.

HWCY is confirming the usage of cookies in its website and this is mainly used for purposes of system analytics of our website and efficiency of system administration. Based on this, HWCY is enabled to obtain information regarding the number of visitors on the website etc.

Any information retrieved it is not shared or communicated by HWCY to any third parties. Personal details such as name, address, gender etc are not stored via the use of our cookies but aim to improve the experience of the visitors.

It is important to understand that Cookies used on our website do not harm or damage the system of the visitors in any way. The visitor may and can reset their browser to amend cookie acceptance.

For deleting or managing cookies on browsers, we highly recommend visiting https://www.aboutcookies.org/