On 25th of May 2018, all companies became subject to the General Data Protection Regulation (GDPR), which puts safeguards into the company's process in the way Personal Data is protected. The General Data Protection Regulation (GDPR) (EU) 2016/679 is the EU regulation on data protection and privacy for all individuals within the European Union and the European Economic Area. This was an essential step to strengthen Your fundamental rights and to enhance legal certainty.
Wise Wolves Capital (EU) Ltd, is a company registered under the laws of the Republic of Cyprus with Registration Number HE 360935 and office address at 30B, Gladstonos, 3041, Limassol, Cyprus and having a license of Administrative Services Provider regulated by the Cyprus Securities and Exchange Commission ("CySEC") under license number 186/196, hereinafter referred to as "WWC" or the "Company".
WWC respects Your privacy and recognizes Your right for transparency and integrity as to the way of collection and processing of Your Personal Data.
"Controller" - means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
"Personal Data" - means any information relating to an identified or identifiable natural person (name, ID, location and any other factors specific to the physical, genetic, mental, economic, cultural or social identity of that natural person); The information for the legal entities such as businesses, partnerships, trusts or other organizations provided by its authorized person, signatory, partner, trustee, executor or a like shall be considered as appropriate.
"Processor" - means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller;
"Processing" - means obtaining, recording, storing, holding, using or carrying out any operation or set of operations on the information or data including organization, adaptation or consultation on the information or data, as well as disclosure by transmission, dissemination or otherwise making available, or alimenting, combining, blocking, removing or destructing of the information or data;
"Sub-Processor" - any processor engaged by the data importer or by any other sub-processor of the data importer and who agrees to receive from the data importer or from any other sub-processor of the data importer personal data exclusively intended for the processing activities to be carried out on behalf of the data exporter after the transfer in accordance with the data exporter's instructions.
WHAT INFORMATION WE COLLECT FROM YOU
WWC is required to collect the following Personal Data:
- Personal information (name, address, email, telephone number, mobile number, temporary residential address, employment address, name of employer, personal status, i.e. identity card number, passport number, marital status, occupation, country of taxation and other);
- Financial information (income, source and size of wealth and other).
WWC is also required to collect and keep all the documents which confirm the accuracy of provided personal and financial information (passport, ID, Utility Bills, Bank Statements, Internal passports, Bank References, CVs or any other information which may be requested by the Company in order to comply with the applicable law.
We always make sure that all Personal Data we collect is adequate, relevant and limited to what is necessary in relation to the purposes for which it was collected and processed.
In cases where we receive data which was not requested or where information was unintentionally revealed, and the Company does not intend to use it for the purposes of processing or where data was received by mistake, WWC shall notify You that such data was received and destroy it, unless You wish otherwise.
WHY WE COLLECT YOUR INFORMATION
According to the GDPR, WWC acts as a Controller of Your Personal Data and determines solely or jointly with others, the main purpose and legal grounds for the collection and processing of Your Personal Data.
WWC has outlined the following purposes and legal grounds:
- Execution of the contract. The collection and processing of Your Personal Data is necessary for entering into business relationship with You for the provision of administrative, fiduciary and other related services by the WWC;
Compliance with legal framework within which WWC operates. Namely, the Law regulating Companies Providing Administrative Services and Related Matters (L196(I)/2012 with amendments), the Prevention and Suspension of Money-Laundering and Terrorist Financing Laws (L188(I)/2007 with amendments), Directive of the Cyprus Securities and Exchange Commission (DI144-2007-08) and other laws, regulations and circulars of the European Union and the Republic of Cyprus applicable to the Company;
Compliance with these regulations requires from the Company to identify personal information related to You and all connected persons, as well as exercise anti-money laundering controls, keeping and collecting Personal Data for the particular period of time and disclose such information to the supervisory and other regulatory authorities;
Legitimate interests pursued by the Company in order to protect its business environment, provided that such interests do not infringe the rights, interests and Your fundamental freedoms.
"Legitimate interests" is a heading that covers several different reasons why WWC may need to collect and process Your Personal Data which may not be covered by other headings, such as: to prevent fraud or financial crime, to provide a better service, to transfer Personal Data between group entities for internal administrative purposes, or for the purposes of network or information security.
CATEGORIES OF RECIPIENTS OF YOUR PERSONAL DATA
Your Personal Data in the course of performing our contractual and statutory obligations may be disclosed to the following Processors or Sub-Processors:
- Supervisory and other regulatory and public authorities, including government al bodies;
- External auditors, lawyers, agents, consultants and other professional advisors subject to confidentiality agreements;
- Banks and other financial organizations subject to the confidentiality agreements;
- Employees of Wise Wolves Capital (EU) Ltd;
- Affiliated companies within the Wise Wolves Group Ltd.
WWC may be required to transfer the information provided by You outside of the European Economic Area (for example, to the banks of the Russian Federation) for the purposes of executing the services provided in a manner as described under the WWC's Internal Policies. Such transfer is subject to Article 49(1)(b) and Article 49(1)(c) of the GDPR.
Our Company ensures an adequate level of protection for any Personal Data processed by others on behalf of WWC that it is transferred within or outside the European Economic Area.
Unless expressly declared by You, the Personal Data collected and keeping by WWC will not be disclosed to any third party other than the above-mentioned recipients.
KEEPING PERSONAL DATA
In accordance with the laws and regulations of the Republic of Cyprus, WWC is obliged to keep and update Your Personal Data for as long as WWC provides its services to You. Upon the termination of the business relationship, Your Personal Data shall be kept for a minimum of five  years. After the legally required period lapses, your Personal Data shall be destroyed.
However, we will be required to keep Your Personal Data for the longer period of time if it is prescribed by laws, competent authorities or other regulations (such as pending legal proceedings or investigations).
WWC takes all reasonable and appropriate steps to protect Your personal information from misuse, loss or unauthorized disclosure. The Company is doing this by having a range of appropriate technical and organizational measures.
You have the following rights in relation to the Personal Data provided by You to the Company:
- The right of access to or have a copy of Personal Data as well as some supplementary information on that data;
- The right to request rectification of incorrect data concerning You;
- The right for data portability if it should become relevant;
- The right to request, on legitimate grounds the erasure of Your Personal Data;
- The right to object the processing of Personal Data based on WWC legitimate interests and/or processing of Personal Data for direct marketing purposes;
- The right to restrict processing of Your Personal Data;
- The right to withdraw consent, by written notice, if the process of Your data is based on consent. Please note that this will not affect the lawfulness of processing based on consent before it was withdrawn by You;
Please feel free to exercise the above rights by sending the relevant email to GDPR@wise-wolves.com.
Furthermore, You have a right to lodge a complaint regarding the processing of Your Personal Data by WWC by sending a complaint to GDPR@wise-wolves.com and the Company's responsible officer will investigate the matter. In case where You are not satisfied with WWC's response or if You feel that Your concerns have not been adequately addressed by the Company, You have a right to file a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus.
PERSONAL DATA BREACH NOTIFICATION
In case the Company becomes aware of Personal Data breach which may result in high risk to Your rights and freedoms, the Company shall without undue delay notify You of such breach and provide the following information:
- Type of Personal Data affected;
- The nature of breach;
- Steps the Company shall take in order to minimize any damage.
You should inform the Company immediately by sending an email to GDPR@wise-wolves.com of any possible damage, loss or misuse such breach may cause to You in order to assist WWC access all possible solutions promptly.
This document is only available in English. Any translated copies are not valid.