Privacy policy

Introduction

MyCyprusTax respects your privacy and is committed to protecting your personal data. This privacy policy lets you know how we look after your personal data when you visit our Website (regardless of where you visit from) and about your privacy rights.

  1. Important information

Purpose of this privacy policy

This privacy policy tells you how MyCyprusTax collects and processes your personal data when you use https://www.MyCyprusTax.com and any subdomains (known as Websites). It also refers to any Services we provide through the Website., including via any API or application we may publish (known as “Services”).

The Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

Evidentrust Financial Services Ltd, trading as MyCyprusTax (collectively referred to as “MyCyprusTax”, “we”, “us” or “our”), is considered a data controller and is responsible for keeping your personal data safe.

We have appointed a data privacy manager who is responsible for this privacy policy. If you have any questions, including any requests to exercise your legal rights, please contact the data privacy manager using the details below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in a way that suits you:

Complaints

If you have concerns about the way your data has been managed, please let us know in the first instance. We’d like the chance to investigate and make things right, if needed. But, you do have the right to make a complaint at any time to the Cyprus Data Protection Officer –  the Cyprus supervisory body for data protection issues (www.dataprotection.gov.cy).

Changes to the privacy policy and your responsibility to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current so that we can better serve you. Please let us know if your personal details change at any time.

Third-party links

The Website may include links to third-party Websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these Websites and are not responsible for their privacy practices. When you leave our Website, please read their privacy policy.

  1. The data we collect about you

Personal data is any information about you from which you can be identified. It does not include data where your  identity or identifiable personal information has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity data: name, social insurance number and Tax Identification Code.
  • Contact data: address, phone number and email address.
  • Financial data: bank account and payment card details.
  • Transaction data: details about payments to and from you and other details of Services you have purchased from us.
  • Technical data: 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 our Website.
  • Accounting data: financial documents such as payslips, invoices, and financial details such as your income and expenses.
  • Marketing and communications data: your preferences in receiving marketing from us and our third parties (namely your MyCyprusTax accountant), and your communication preferences.

We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not legally considered personal data will 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. However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we will treat the combined data as personal data which will be used according to this privacy policy.

We do not collect any special categories of personal data about you (including: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

If you fail to provide personal data

If we need to collect your personal data by law, or under the terms of a contract we have with you, and you do not 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 goods or services). In this case, we may have to cancel a product or service you have with us. But we will notify you about this at the time.

  1. 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, contact, financial and accounting data by filling in forms or by corresponding with us by post, phone, email or otherwise.This includes personal data you provide when you:
    • create an account on our Website;
    • subscribe to our Services;
    • use a tax calculator on our Website;
    • request information or marketing from us;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. We may also receive technical data about you if you visit other Websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Technical data from:
      (a) analytics providers;
      (b) advertising networks; and
      (c) search information providers.
    • Financial and transaction data from providers of technical, payment and delivery services.
    • Accounting data from Social Insurance and other government bodies.

  1. 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 situations:

  • 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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

Why we will use your personal data

We have set out below descriptions of all the ways we plan to use your personal data. We also include any legal basis and/or rationale we have to do so we may process your personal data for more than one reason. Please contact us if you need details about the specific legal ground we are relying on to process any of your personal data where more than one ground has been set out below.

Purpose/Activity Type of data Lawful basis for processing data, including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact		 Performance of a contract

To process and deliver your order including:
(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and communications
(f) Accounting

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you, which will include:
(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 (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 customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey. (a) Identity
(b) Contact
(c) Marketing and communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).

 (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 deliver relevant Website content and advertisements to you, and to measure or understand the effectiveness of the advertising we serve to you. (a) Identity
(b) Contact
(c) Marketing and communications
(d) Technical		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To disclose your personal data to your nominated accountant. (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Accounting		 Contractual performance
To make suggestions and recommendations to you about Services that may be of interest to you. (a) Identity
(b) Contact
(c) Technical
(d) Marketing and communications
(e) Accounting		 Necessary for our legitimate interests (to develop our products/services and grow our business).

Marketing

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

Promotional offers from us

We may use your identity, contact and technical data to form a view on what we believe you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased Services from us, and you have not opted out of receiving such communications.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by contacting us at any time.

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 our Website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the reasons we collected it, unless we reasonably believe that we need to use it for another reason that 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 get in touch.

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.

  1. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • External third parties in the following categories:
    (a) Communication and administration: Google, Mailchimp, Microsoft;
    (b) Analytics, tracking and website functionality: Google, Insights;
    (b) Accounting: Manager;
    (c) Payments: Stripe, Paypall;
    (d) Anti-money laundering compliance: Zygos;
    (e) External accountants.
  • 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 policy.

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 allow them to process your personal data for specified purposes and in accordance with our instructions.

  1. International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal at the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data security

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 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.

  1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may keep your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

  1. Your legal rights

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

  • 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 the 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 basis 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;
    (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 of your choice, 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 let you know  if this is the case when you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 other 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 could 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.