Last update: 8 June 2019
K. A. Kourtellos & Co LLC and our affiliated businesses or associates (collectively, “KAK”) are committed to respecting and protecting the personal information you or your organisation provide to us and the information we collect for the purpose of operating our business.
“Personal Information” means any information that can be used to identify an individual or that we can connect to a person. Such Personal Information does not consist of anonymous data.
In this Policy you will find a description of how KAK may collect, use, protect, store and share Personal Information, particularly in relation to our website and social media accounts (“Digital Accounts”) and any other link to this Policy. This Policy has been prepared using brevity and may be amended from time to time. You may periodically review this Policy. If we make any material changes in this Policy we will notify you via our Digital Accounts.
We process Personal Information in accordance with the EU General Data Protection Regulation and the applicable national legislation and regulations, as amended from time to time.
This Policy describes:
How to contact us
K. A. Kourtellos & Co LLC is the entity responsible for processing your Personal Information.
If you would like to contact us with questions about our data protection or privacy practices, please contact our Data Protection Officer via email at firstname.lastname@example.org or via telephone at +357 25257003.
The types of Personal Information we collect
The types of data we collect largely depend on the service or product that you request from us and our business relation. We collect Personal Information you voluntarily provide to us, including when you communicate with us via email or otherwise, when you sign up for our newsletters, alerts, webinars, events or other matters, when you submit an application to work with us, and when you respond to our requests for information. Such information may be your name, contact details, title and information about your organisation. We may collect certain information when you use, access, or interact with our Digital Accounts. Any sensitive data is collected on the basis of your consent or limited statutory purposes.
Moreover, third parties, affiliated businesses and associates that we cooperate with may provide us with your Personal Information for the purpose of our business operations. We may collect information from other public sources, such as social media platforms that may share information about how you interact with our social media content. Such collection of information is governed by the privacy settings, policies and procedures of the social media platform which you may periodically review.
How we use the Personal Information we collect
We may use your data as follows:
We do not use automated decision-making i.e. without any human involvement; however we may notify you accordingly if we do so.
How we may disclose the Personal Information we collect
For the purpose of providing our services we share information with our affiliated businesses or associates to undertake internal administration, billing, promotion of our events, services and products, and provide you with our services or products.
We do not disclose, sell, rent or otherwise share your Personal Information with any third parties or unaffiliated entities for their independent use, except as expressly stipulated in this Policy or with your prior consent. We may share data that does not reasonably identify you to the extent permitted by applicable laws or regulations.
In addition, we may disclose your data as follows:
Legal grounds for processing your Personal Information
We process your Personal Information on the basis of the following legal grounds:
Third party interactions
How we protect and store the Personal Information we collect
We put in place appropriate administrative, technical and physical safeguards for the purpose of compliance with applicable legal and regulatory requirements to protect and store the Personal Information we collect. You will appreciate no information system can be entirely secure, therefore we cannot guarantee absolute security of your information nor be responsible for the security of any information you send to us over networks outside our control.
Our Digital Content is controlled from and stored in Cyprus or other countries where our affiliated businesses or associates operate. We may transfer information to countries which may have different data protection and privacy laws or regulations. We may transfer data to countries outside the European Union (EU) or European Economic Area (EEA) if we are required by any applicable laws or regulations or upon your consent to do so. Any transfers of information from the EU to countries outside the EEA will be made on the basis of specific requirements, including the model clauses approved by the European Commission (EC) for transfers from EU controllers to non-EU controllers, which may be found at the EC website.
We keep the information we collect for as long as you require our services or products or as reasonably necessary to fulfil the purposes for which we collect such information and to comply with our legal and regulatory requirements.
Your choices and rights
You may elect to no longer receive marketing communications from us by letting us know via email at email@example.com or by using the opt-out mechanisms provided to submit your marketing preferences.
Do let us know if your information changes or if any information we collected about you is inaccurate to update or correct it accordingly.
You can ask us to inform you what Personal Information we hold (i.e. data subject access request), to erase such Personal Information if there is no further reason for us continuing to process it or if you object to our use of such Personal Information. You may also request restriction of processing your Personal Information. We may not always be in a position to comply with such request for erasure or restriction or if you object to our use of such Personal Information, if we have specific legal reasons or compelling legitimate grounds which we will be notified to you if applicable upon your request.
You may also request that we transfer your Personal Information to you or to a third party and, if the processing of your Personal Information takes place on the basis of your consent, withdraw consent at your discretion. In such event we will notify you if we will no longer be in a position to provide our services or products.
If you would like to exercise the rights you may have, please contact us at firstname.lastname@example.org. Any excessive, unfounded or repetitive requests will be subject to additional administrative fees, as appropriate.
Do inform us if you are not satisfied with how we used your Personal Information. You may also submit a complaint to the national Data Protection Commissioner.