This is the privacy policy (“Privacy Policy”) of the ANELLI Services Ltd.

Hereby we would like to explain what information we collect from you or you provide to us, how we use it and with whom we share that information. The Privacy Policy also sets out your rights and who you can contact for more information.

The European General Data Protection Regulation ((EU) 2016/679) (hereinafter referred as the GDPR), has been in force since 25th of May 2018.

In order ANELLI Services Ltd to be duly complied with the above Regulation we would like to inform you that ANELLI Services Ltd is a subject to the GDPR and henceforth is the data controller of your personal data.

We are committed to protecting and respecting your privacy and handling your information in an open and transparent manner. This Policy is subject to periodic review and any changes will be included within this section of the site.

In this Privacy Policy, your information we collect from you or you provide to us, may sometimes be called “personal data”. “Processing” in this case shall mean handling, collecting, protecting and storing your personal data.

In this Privacy Policy the term “Data Protection Regulation” shall mean the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.

For the purposes of Data Protection Regulation the data controller is ANELLI Services Ltd.

Content

1. What personal information do we collect?
2. How is your personal information collected?
3. Why we collect personal data
4. How will we use your personal data?
5. Your rights
6. Data Retention
7. Data Sharing
8. Contacting us

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1. What personal information do we collect?

We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Regulation and as set out in this Privacy Policy.

The personal data we collect may include:

·       Personal identity data such as your name, job title, postal address, including your home address, where you have provided this to us, business address, telephone number, mobile phone number, fax number and email address;

·       Financial data, such as data necessary for processing payments, including credit/debit card numbers, bank account and other related financial information;

·       Further financial and/or business information necessarily processed in a client contractual relationship with ANELLI Services Ltd or voluntarily provided by you, such as instructions given, payments made, requests and projects;

·       Information collected from publicly available resources, integrity data bases and credit agencies where this is relevant to the services offered to you;

·       Further identity data such as marital status, date of birth, passport number, photographic identification and gender if legally required for KYC/compliance purposes or other relevant data related to you or in interaction with you; ·       Other personal data regarding your preferences where it is relevant to the services that we provide;

2. How is your personal information collected?

We may collect personal data about you in a certain circumstance, including:

·      When you or your company request corporate, administrative company secretarial services from us;

·       When you or your company browse, submit a request or otherwise interact on our website;

·       When you or your company offer to provide or provide services to us and/or clients.

In some circumstances, we collect personal data about you from a third-party source. For example, we may collect personal data from your organisation, other organisations with whom you have dealings, government agencies, an information or service provider or from a publicly available record.

3. Why we collect personal data

Your personal data is processed by ANELLI Services Ltd on the basis of:

• contracts and agreements for providing our services to you or your company and for contracts and agreements of which you are a party. ANELLI Services Ltd may also process your personal data in order to make all necessary arrangements prior entering into a contract or agreement with you. We will process only the personal data necessary for the execution of the contract and agreement;

• legal obligation and specifically the Cyprus Anti-Money Laundering and Combating Money Laundering Laws, as amended from time to time, (hereinafter referred as The AML Law) to perform Due Diligence procedure on you or your company as our Client and to all individual which may be the Beneficiaries of the services obtained from ANELLI Services Ltd and/or may control the legal entity for which ANELLI Services Ltd provides corporate, administrative or secretarial services;

As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, it will unfortunately not be possible for us to provide you with what you request without first obtaining the relevant personal data and we will notify you accordingly.

4. How will we use your personal data?

We may use your personal data for the following purposes only (“Permitted Purposes”):

• Providing contractual services, you may have requested that relate to our offered services;
• In order for us to comply with our legal obligations (such as record-keeping obligations), compliance checks and monitoring, or recording obligations (e.g. for anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes), which may include automated checks on some of your personal data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for compliance purposes;
• To analyze and improve our services and communications to you;
• Protecting the security of and managing access to our premises, IT and communication systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
• For monitoring and assessing compliance with our policies and standards;
• To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
• To comply with court orders and exercises and/or defend our legal rights; and
• For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.

Where you have expressly given us your consent, we may process your personal data also for communicating with you through the channels you have approved to keep you up to date on the latest legal developments, announcements, and other information about our services and products.

With regard to marketing-related communication, we will – where legally required – only provide you with such information after you have opted in and provide you the opportunity to opt out anytime if you do not want to receive further marketing-related communication from us. We will not use your personal data for taking any automated decisions affecting you or creating profiles other than described above.

Depending on for which of the above Permitted Purposes we use your personal data, we may process your personal data on one or more of the following legal grounds:

·       Because processing is necessary for the performance of contractual obligation with you or your company;

·       To comply with our legal obligations (e.g. for compliance purposes); or

·       Because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

In addition, the processing may be based on your consent where you have expressly given that to us.

5. Your rights.

One of the most important part of the GDPR is the personal data subject rights arising from the GDPR. ANELLI Services Ltd would like to inform you about your rights which you may exercise at any time:

• to request from the data controller access on your personal data;
• to request from the data controller the rectification of your personal data;
• to require from the data controller not to send any marketing communication;
• to request from the data controller to erase your personal data;
• to request from the data controller to cease the processing of personal data for any reason;
• to object on processing your personal data or to demand the restriction of processing your personal data,
• to lodge a complaint with a supervisory authority.

The supervisory authority in Cyprus is the Commissioner of Data Protection. You can lodge the complaint through mail at the following address:

1 Iasonos Str., 1082, Nicosia, Cyprus; or by following the instruction on their web-site http://www.dataprotection.gov.cy.

Please note that the above rights are not absolute, and ANELLI Services Ltd may be intitle to refuse a request when exception applies.

In addition, ANELLI Services Ltd strongly recommends to visit wed-site of the Commissioner for Data Protection in Cyprus which is the regulatory authority and where you can be further informed for your rights. www.dataprotection.gov.cy

6. Data Retention

In order to fulfil the abovementioned Permitted Purposes we are obliged to maintain the personal data which is stated in the Data Protection Regulation, AML Laws and/or other applicable legislations, during our business relationship and for the period of five (5) years after the end of business relationship between ANELLI Services Ltd and you or your company.

7. Data Sharing

For the purposes to comply with our legal obligations and/or to perform and execute the agreements and contacts; ANELLI Services Ltd may share your personal data with the following:

• any person properly authorized by you;
• your representatives, agents, advisers that you will indicate;
• our professional advisers where it is necessary for ANELLI Services Ltd to obtain their advice or assistance including lawyers, auditors and accounts;
• third parties such as accountants, auditors, agents in different jurisdictions (when applicable), with whom we engage to assist in delivering the services to you;
• Cyprus authorities such as the Department of Registrar of Companies and Official Receiver, Tax, VAT, Social Insurance Services authorities and any other authorities for the purposes mentioned above;
• banks and financial institutions.

Separate consent will be obtained in case of sharing personal data with any third party not stated above.

The data processing may be carried out on behalf of us by a third-party data processor, pursuant to written and express authorization for specific purposes contained in the relevant authorization. The third party will be controlled and supervised by ANELLI Services Ltd in order the processing of the personal data to be compliant with GDPR and in order the rights of the data subject to be insured. Further ANELLI Services Ltd has taken all the necessary and appropriate technical and legal measures to meet the standards of GDPR and to minimize any risks.

In order to deliver the services and/or to execute the contracts and agreements ANELLI Services Ltd may share the personal data with parties outside the European Union.

During our contractual and business relationship and after the end of it, we may be obligated based on the legislations or to Court Order to disclose some or all of the personal data possessed to regulator authorities or competent authorities.

8. Contacting us

Please contact ANELLI Services Ltd at any time should you have any questions or concerns with regards to GDPR or you wish to exercise any or all rights mentioned above.

Data Controller’s info:

ANELLI Services Ltd

Address: 8, Rigas Fereos Street 3rd floor, Agios Nikolaos 3095 Limassol, Cyprus

Phone Number: 25022830

Fax Number: 25721188

Email address: info@anelliservices.com