Privacy Policy of GP Global Management Ltd
This Privacy Policy explains how GP Global Management Ltd ("we", "our", "us") handles your personal data as part of the provision of GP Global Management Ltd services to you as a Client. 

This Privacy Policy describes how we collect, use, process and store your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is of the utmost importance to us and we are committed to comply with the EU Regulation (EU) 2016/679 to protecting and safeguarding your data privacy rights. 

This Privacy Policy is based on our data Protection Policies and Measures. 

This Privacy Policy is available through the GP Global Ltd website and does not apply to the collection of Personal Data through this website or through cookies with respect to which Personal data GP Global Management Ltd can be considered Controller. Please refer to our separate website Privacy Notice and Cookies Policy for more information in regards the Privacy Notice of this website. 

INFORMATION ABOUT US

We are GP Global Management Ltd
Our registered office is at 7, Alkaios Str., Alkaios Court, Flat 103, 3090 Limassol – Cyprus.
If you have any questions, our contact details are:
Mail address: Our mail address is as stated above 
Email: gpinfo@cytanet.com.cy
Tel: 00357-25755911
Fax: 00357-25755660

WHY WE HAVE A PRIVACY POLICY

In accordance your request for the provisions of our services to you and for the purpose of applicable data protection legislation Regulation (EU) 2016/679, GP Global Management Ltd is the data controller of your personal information.  

GP Global Management Ltd is committed to protecting and respecting your personal data. 

It is our legal obligation, under the Anti Money Regulation, to collect, use and store your personal data.

GP Global Management Ltd will maintain the confidentiality and protect client’s information in accordance with its normal procedures and all applicable laws, including the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and/or other relevant Cyprus laws and/or regulations issued there under.

If for any reason you are dissatisfied with the Privacy Policy of GP Global Management Ltd, you have the right to end this transaction without submitting any personal information. 

THE PURPOSE OF PROCESSING

The processing of your personal information by GP Global Management Ltd is for the purpose of: 
 processing is necessary for the performance of a contract to which you are a part or in order to take steps at your request prior to entering into a contract;
 processing is necessary for compliance with a legal obligation to which we are subject;
 processing is necessary for the purposes of our legitimate interests or of the legitimate interest pursued by a third party;
 processing when you give your consent of the processing of your Personal Data for specific purposes. In such case, you can withdraw your consent at any time

If for any reason, we intend to further process your personal information for a purpose other than that for which your personal information were collected, we shall provide you, prior to that further processing, with information on that other purpose and with any relevant further information.

CHANGES TO THIS PRIVACY POLICY

Please note that this Privacy Policy may change from time to time in order to adapt to new legal requirements. Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. We encourage you to regularly review this Privacy Policy to see any updates or changes

INFORMATION THAT YOU PROVIDE TO US

In order to provide our services that you have requested and for the whole duration of your business relationship with us, we need to process certain information about you. We only ask for personal information that we are obliged to collect from you under our legal obligations and are relevant to your specific requests for the provision of our services. 
These information include among others your personal contact details, documents to verify your identify and residential address, tax identification documents, data and documents for your financial situation, employment and education, information to understand the reason of requesting the provisions of our services,  information to assess whether you may represent a politically exposed person.
If you would like a more detailed description of the personal data that we collect about you, please contact us at gpinfo@cytanet.com.cy.

We may use a number of ways to collect your personal information like for example:
 From a face to face meeting,
 From your company or an intermediary,
 Through a communication with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication,
 When you or we on your behalf complete an "Account Opening" application or other on-boarding forms.

You are committed to supplying true, complete and accurate information and to keeping it up to date. If you are in any doubt about any personal data, please feel free to email us at gpinfo@cytanet.com.cy with details of the problem first. We shall take every reasonable step to ensure that inaccurate data, having regard to the purposes for which they are processed, are erased or rectified without delay.

GP Global Management may store information and data regarding your bank account, credit/ debit card details or other payment account information under requirements of the Law.

INFORMATION WE RECEIVE FROM OTHER SOURCES 

Where appropriate we may seek more information about you from other sources generally by way of due diligence or other market intelligence including:
 Business partners,
 Third parties,
 Your agents, advisers, intermediaries,
 Publicly available sources,
 Credit reference agencies.

We may use these information as a decision point to start or continue the provision of our services to you as you have requested.

CHILDREN’S PERSONAL DATA

Our services are not intended for or targeted at children under 16 years old. GP Global Management Ltd does not knowingly solicit or collect personal data from children below the age of 16. However, if we collect and use information about children below the age of 16 years, we will comply with applicable Regulation (EU) 2016/679.

UPDATING YOUR DETAILS

GP Global Management Ltd will ask you from time to time, under our legal obligation for the provision of our services to you, to confirm what information we hold about you are accurate. 
GP Global Management Ltd may ask you to have incomplete personal data completed. A "Supplementary Form" will be given or send to you for this purpose.
Where your data has been passed to a third party with your consent or for legal reasons, we will communicate any update to them, unless this proves impossible or involves disproportionate effort. 
GP Global Management Ltd may ask you from time to time to provide more information about you in accordance our obligations to comply with any new legal requirements.

YOUR RIGHTS AND YOUR PERSONAL DATA

Unless subject to a restriction under the GDPR Regulation (EU) 2016/679 and under the legal obligation we are subject to, you have the following rights with respect to your personal data:
 Right of access. You have the right to request a copy of your personal data which the GP Global Management Ltd holds about you. We may charge a reasonable fee (as permitted under GDPR Regulation (EU) 2016/679 Article 15(3) based on administrative costs involved in processing your request to access your Personal Data.
 Right to rectification. You have the right to request that GP Global Management Ltd corrects any personal data if it is found to be inaccurate or out of date;
 Right to erasure. You have the right under certain circumstances your personal data to be erased;
 Right to restriction of processing. Where there is a dispute in relation to the accuracy or processing of your personal data, you have the right to request a restriction on further processing, in accordance GDPR Regulation (EU) 2016/679 provisions;
 Right to data portability. Where the processing is based on consent or on a contract and the processing is carried out by automated means, you have the right to receive the personal data and have the right to transmit those data to another controller;
 Right to object. Where applicable under the GDPR Regulation (EU) 2016/679, you have the right to object to the processing of your personal data;
 Right not to be subject to a decision based solely on automated processing, including profiling;
 Right to withdraw your consent. Where the processing is based on your consent, you have the right to withdraw your consent at any time. To withdraw your consent, send an email to gpinfo@cytanet.com.cy asking to withdraw your consent;
 Right to lodge a complaint with the Cyprus Supervisory Authority.

To exercise all relevant rights, queries or complaints, please in the first instance contact GP Global Management Ltd at gpinfo@cytanet.com.cy.  

To exercise your rights, we may ask from you to provide additional information to enable your identification in case we have reasonable doubts concerning the identity of the person making the request. We may refuse to act on the request of you to exercise your rights in case we are not in position to identify you.

We may provide the information you have requested, under your rights, in writing or by other means. If you request to be provided with the information orally, first we have to verify your identity by other means.

We will act in accordance your request when you exercise your rights within one (1) month of receipt of your request. This period may be extended by two (2) further months where necessary and you will be informed for such extension accordingly.

MARKETING INFORMATION

GP Global Management Ltd may periodically send you promotional emails about new services, special offers, newsletters or other information which we think you may find interesting using the email address which you have provided. From time to time, we may also use your information to contact you for market research purposes, although you do not have to respond to them. We may contact you by email, phone, fax or mail when available. 
In this respect, when we send you any marketing email, you will be given automatically the opportunity to object any time to processing of personal data concerning you for such marketing. You will have the opportunity to opt out of further promotional offers by replying to the email. 

WHEN WE SHARE PERSONAL INFORMATION

We may disclose your Personal information, when necessary, with third parties for the performance of our business operations. When we share personal information, we do so in accordance with data privacy requirements. Third parties may be:
 Your agents, advisers, intermediaries who you tell us about;
 Business parties whom we engage to assist in delivering the services to you, including other related to us companies;
 Our professional advisers including lawyers, accountants, IT, where it is necessary for us to obtain their advice or/and assistance;
 Other third parties such as intermediaries and business introducers;
 Our data storage providers;
 Our system support providers.

We may be required to disclose your Personal Information to relevant recipients if it is required to do so by law.

GP Global Management Ltd cannot ensure that a third party will not unlawfully access private details.

TRANSFER OF YOUR PERSONAL INFORMATION TO THIRD COUNTRIES 

As set out in this Privacy Policy, the sharing of your personal information with third parties may include the transfer of your personal information outside the European Union. In such case, your personal information will be transferred on one of the following conditions: 
 the third country where we shall transfer your personal information has been approved by the European Commission as ensuring an adequate level of protection for personal information;
 you have consented to the proposed transfer; 
 the transfer is necessary for the performance of a contract between you and us;
 the transfer is necessary for important reasons of public interest, for the establishment, exercise or defence of legal claims;
 the transfer is necessary in order to protect your vital interests or of other persons, in case you are physically or legally incapable of giving consent;
 the transfer is made from a public register.

FOR HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We will retain your personal data for no longer that is necessary for the purposes for which the personal data are processed. 
In accordance our legal obligations, where we have collected your personal data as required by anti-money laundering legislation, we will retain your personal information for a period of at least five (5) years, after the termination of the business relationship, unless we are required to retain your personal information by another law or for ongoing court proceeding purposes or for ongoing investigations by relevant authorities. 

SECURITY AND CONFIDENTIALITY

We recognize the importance of guarding the security of your personal information and on-line communications. We have measures in place to protect against accidental loss and destruction (backup) and unauthorized processing. We restrict access to personal data that is collected about you to only those who have a need to know that information in connection with the purposes for which it is collected and used. We employ individuals, who are suitably qualified, possess the necessary technical knowledge and personal integrity for maintaining confidentiality. Additionally, we maintain physical, electronic, and procedural safeguards to guard your personal data. 

The transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored. 

APPLICABLE LAW

This Privacy Policy is subject to the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 and Laws of Cyprus.
GP Global Management Ltd welcomes your comments regarding this Privacy Policy. If you believe that GP Global Management Ltd has not adhered to this Privacy Policy, please contact GP Global Management Ltd at gpinfo@cytanet.com.cy. We will use commercially reasonable efforts to promptly determine and remedy the problem.

This policy was last updated on 25/05/2018



Our Location
7, Alkaios street, Alkaios Court, Flat 103
3090 Limassol, CYPRUS

P.O. Box 59565
4010 Limassol, CYPRUS
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