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The site uses cookies to provide you with a better experience. By using this site you agree to our Privacy policy.

Privacy policy

Introduction

Welcome to Moore Limassol Limited privacy notice.

Moore Limassol Limited (registration number HE 203824) is a full member of Moore Global, which is one of the leading international accounting and consulting groups.

Moore Limassol Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to why and how we collect and use your personal data, how we look after such data and provide you with information about your privacy rights and how the law protects you.

This privacy notice applies to personal data provided to Moore Limassol Limited, both by individuals, companies and others.

Please note that Moore Limassol Limited processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ. 

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Moore Limassol Limited collects and processes your personal data.

Moore Limassol Limited may use personal data provided to us for any of the purposes described in this privacy notice or as otherwise stated at the point of collection.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Moore Limassol Limited is the controller and responsible for your personal data (referred to as “Moore Limassol Limited”, "we", "us" or "our" in this privacy notice). This is generally the role under which we process personal data.

If you have any questions about this privacy notice, including any requests to exercise your legal rights (as set out below), please contact us using the details set out below.

Contact details

Moore Limassol Limited
Email address: info@moore-limassol.com.cy

Postal address: Ariel Corner, 1st Floor, Office 102, 196 Makarios Avenue, 3030 Limassol, Cyprus

Telephone number: +357 25-820280

You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, the Cyprus supervisory authority for data protection issues (http://www.dataprotection.gov.cy). We would, however, appreciate the chance to deal with your concerns before you approach the Office of the Commissioner for Personal Data Protection so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 10/6/2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Any changes we make to our Privacy Notice in the future will be posted on this page and will be communicated to in the way that you received this Privacy Notice.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
 
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, country of residence.
  • Contact Data includes billing address, postal address, email address and telephone numbers.
  • Financial Data includes bank account, payment card details, salary, payroll details and other financial-related details such as income, investments and other financial interests, benefits, tax status.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • Interest and Engagement Data includes Know Your Client data (passport copy, CV, utility bill, bank statement and questionnaire), data related to your interest in companies and other corporate or unincorporated bodies (such us limited liability companies, trusts and other) and your professional engagements, agreements and other arrangements.
  • Job Details includes role, grade, experience, performance information and other information about management and employees. 
  • Special Categories of Personal Data in certain circumstances, we may also collect and process information on your ethnic or racial origin, religious beliefs and your criminal records or offences or even details as to sex life or preferences (for instance obtained through a disclosure process during a provision of a relevant service).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or your country of origin to calculate the percentage of clients from a specific area. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law or due to our obligations as a certified accountants and auditors company by The Institute of Certified Public Accountants of Cyprus, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with accounting, auditing or other services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:
 
  • Direct interactions. You may give us your Identity, Job Details, Contact, Interest and Engagement and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • request marketing to be sent to you;
    • contact us about our services by email, telephone or through our website;
    • fill out application forms, telephone or through our website;
    • send us CVs or resumes;
    • participate in interviews, meetings and other assessments;
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • (a) analytics providers such as Google based outside the EU;
      • (b) advertising networks such as Facebook and LinkedIn based inside/outside the EU; and
We may receive personal data about you from various third parties as set out below:
 
  • From the organisation in which you are employed;
  • From other parties involved in a matter which we are dealing with;
  • Information available in the public domain;
  • Private investigators;
  • Governmental authorities, agencies, departments and organisations;
  • Recruitment Agencies (including websites such as Ergodotisi.com, Carierista.com, CyprusJobs.com);
  • Personal references, from ex-employers for instance;
  • Background check providers;
  • Credit reference agencies.
4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
 
  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
Please refer to the below section to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at info@moore-limassol.com.cy  if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
 
Purpose/Activity Type of data Lawful basis for processing including
basis of legitimate interest
To register you or your employer as a new client or when you get in touch with us. (a) Identity (e.g. name, age/date of birth, gender, marital status, country of residence);
(b) Contact (e.g. email address, contact number, postal address);
(c)Interest and Engagement
(d) Job Details (e.g. role, grade, experience, performance information and other information about management and employees). 
(e) Special Categories (a) Performance of a contract with you or your employer;
(a) Performance of a contract with you or your employer;
(c) Necessary for our legitimate interest to protect our business, employees and premises and to prevent fraud.
Administering, performing, managing and developing our business and services including:
(a) providing accounting, payroll and auditing services and to advice in financial, business or other matters;
(b) Manage payments, fees and charges;
(c) Collect and recover money owed to us;
(d) managing our relationship with clients;
(e) developing our business and services (such as identifying client needs and improvements in service delivery and learning more about a client, relationship opportunity.
(a) Identity
(b) Contact
(c) Financial 
(d) Transaction
(e) Interest and Engagement
(f) Special Categories
(g) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us);
- to protect our business, employees and premises and to prevent fraud;
- to provide advice and services and handle matters on behalf of our clients;
- to develop business relationships;
- to ensure network and information security and to prevent fraud.
Special Categories:
For certain services or activities, and when required by law or with an individual's consent, we may also collect special categories of personal data.
Suspicion of terrorist financing.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy;
(b) To update our records for internal use and for auditing purposes.
(a) Identity
(b) Contact
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services);
to conduct business on behalf of our clients;
to study how customers use our products/services, and to develop our business and business relationship.
To administer and protect our business and our website (including hosting, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and maintaining and using IT systems (a) Identity
(b) Contact
(c) Technical
 
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, client relationships and experiences (a) Technical
(b) Usage
 
Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you. (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
To consider your application for employment at Moore Limassol Limited. (a) Identity
(b) Contact
(c) Technical
(d) Job Details
(e)Special Categories
Necessary for our legitimate interest in recruiting staff for our business.
Maintaining and promoting equality in the workplace.
Special categories:
Criminal records where required by position held within the Company.
Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Opting out

You have will only be provided with marketing material if you have subscribed to our newsletter or other informative service we offer and you can request us at any time to stop sending you marketing messages at any time by contacting us at moore@moore-limassol.com.cy.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service provided to you.

Data subjects whose personal data we obtain in connection with providing services to our clients

Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data with us where it is strictly needed for those purposes.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.

Where we need to process personal data of a third party to provide our services, we ask our clients to provide the necessary information to the data subjects concerned regarding its use. 

The personal data we only be processed in accordance with the table under Purposes for which we will use your personal data above and solely where such process is required for such purposes

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@moore-limassol.com.cy

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Our Website

Visitors to our website are generally in control of the personal data shared with us.  We may capture limited personal data automatically via the use of cookies and analytics tools on our website.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use click here.

Third party links

Our website may link to third party sites not controlled by us and which do not operate under our privacy practices. When you link to third party sites, our privacy practices no longer apply. We encourage you to review each third party site's privacy policy before disclosing any personally identifiable information.

Children

We understand the importance of protecting children's privacy, especially in an online environment. Our website is not directed at children. We will not knowingly collect or maintain personal information about data subjects under the age of 16, except as part of an engagement to provide professional services to them, their parents, legal guardian or the employer of their parent or legal guardian and only following the express consent of their legal guardian or parent.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
 
  • External Third Parties:
Service providers acting as processors who provide IT and system administration services.

Professional advisers acting as processors including bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.

Regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances.
 
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers and other transfer

Personal data held by us may be transferred to:
 
  • Auditors, Legal advisors, insurers and other professional advisors. We may need to share personal data with our auditors for our audit obligation, our insurer or insurance broker, for example, in the event of a claim and other professional advisors, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business.
  • The police or other governmental and/or regulatory bodies or to other third parties as required by, and in accordance with, applicable law or regulation. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
  • Subcontractors (subject to approval and appropriate agreement) and other providers to help us provide professional services to our clients
  • Third party companies that provide IT, cloud back up, data management, servers and other services that support us in providing our services and manage our internal IT system;
  • Third party companies that otherwise assist us in providing goods, services or information.
We do not transfer your personal data outside the European Economic Area (EEA) unless you request us to.

If we are required for any reason to transfer your personal data outside the EEA we will take all the appropriate steps to ensure that the personal data is provided with adequate safeguards and that all transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU’s requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses.  The European Commission approved standard contractual clauses are available here.

8. Data security

We take the security of all the personal data we hold very seriously. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

As the transmission of data through the internet is not completely secure and, although we do our best to protect it, the transmission of data via our website or email is made at your own risk. After receiving your data, we will endeavour through procedures and security features to secure the data.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at info@moore-limassol.com.cy.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.