Privacy Policy - J Zenonos

J. ZENONOS & ASSOCIATES LLC

Privacy Notice

This privacy notice set out information about J. Zenonos & Associates LLC privacy practices and your rights.

Introduction

We take the protection of your personal data seriously. J. Zenonos and Associates LLC is a well-established dynamic boutique legal office, based in Limassol Cyprus. Reference to ” J. Zenonos”, “we” or “us” in this Privacy Notice shall mean J. Zenonos & Associates LLC. We may amend this Privacy Notice at any given time and for any reason. The updated version will be available by following the “privacy” link on our website footer at www.jzenonos.com . You should check the Privacy Notice regularly for changes and familiarize yourself with such changes.

By submitting data to us and/or using our services, and/or website, you accept and agree that all personal data that you submit may be processed by us in the manner and for the purposes described in this privacy notice, and you agree to the terms and conditions of this Privacy Notice and Terms of Business.

Data Protection Laws

J. Zenonos office is bound by the European Union (“EU”) General Data Protection Regulation 2016/679 (“GDPR”) and local data protection laws. In this Privacy Notice, the terms personal data, controller, processor, data subject, consent, recipient, third party, processing and profiling have meanings given to them in the GDPR. Further to the latter regulations J. Zenonos is also bound by the personal data regulations under Cyprus Law or any other regulations that might apply in which area we conduct business in.

3. Data Controller Contact Details

The Data Controller under this Privacy Notice for processing of person data is:

J. Zenonos & Associates LLC

27 Themidos Street

Limassol

3040

Cyprus

Telephone: +357 25 312580

Facsimile: +357 25 312560

Website: www.jzenonos.com

Data Protection Officer Contact Detail

If you have any questions about this Privacy Notice or about our personal data processing practices, or if you wish to exercise any of your rights as a data subject, you may contact our Data Protection Officer on the following details:

Hanro Gouws

Data Protection Officer

Telephone: +357 25 312580

Email: [email protected]

If you have a complaint about our persona data processing practices, you should first contact our Data Protection Officer. If you are not satisfied with our responses, you have the right to lodge your complaint with the following supervisory authorities:

Data Protection Commission

Iasonos 1, 1082 Nicosia, Cyprus

Telephone: +357 22818456

Website: http://www.dataprotection.gov.cy/

If you are located outside of the EU, you may contact your local data protection authority or any assistance.

Specific Situations in which we may Process Your Personal Data

J. Zenonos process personal data in several different situations. The following sections will deal with what personal data we will process and how we will process such personal data.

5.1 Clients

5.1.1 Type of personal data

To enable us to engage and serve you as our client, we would need to collect some personal data. This personal data may include your name, identity, position, address, contact details, financial details, business details, and data specified in the industry in which you may operate or conduct business. When we collect personal data, we also might need to make copies of your identification documents and passport or business certificates. During the time we render you with serves we may also collect other personal data as prescribed under Section 5.3 hereinunder. This personal data will be collected personally from yourself, alternatively via third parties or public sources.

5.1.2 Purpose of processing

Purpose of processing	Legal basis of processing
Providing legal and other professional service under our engagement letter and/or mandate and to attend to administrative tasks.	To perform within the legal mandate, terms of business, engagement letter with J. Zenonos, or to take any steps prior or after.
Compliance with laws and regulations.	Comply with legal obligations which J. Zenonos LLC is subject.
To communicate with you as our client and to send you engagements about our firm.	To grow and develop our business in respect of services we can offer our clients.

5.1.3 Recipients of personal data

In some instances, we may disclose your personal data to third parties providing J. Zenonos with administrative services, telecommunications, and any other service to support us in providing you with our services. We will always ensure that any third party will comply with our Privacy Notice in keeping your personal data safe. We may in some instances provide your personal data to law enforcement authorities.

5.1.4 Transfer of personal data

Your data may be transferred abroad. When a client’s matter involves other jurisdictions, personal data will be transferred to other countries to enable J. Zenonos to provide the services under such jurisdictional areas.

5.1.5 Retention of personal data

Your personal data will only be retained for as long as it has a legitimate purpose to do so. The retention of such personal data will be for commercial and legal purposes. Depending on the type of service we would need to render, the retention period might be longer, however we generally only retain the information for a period of five (5) years, or when the matter is concluded.

5.1.6 Requirement to provide personal data

It is mandatory to provide us with basic personal data. In the event of no basis personal data being provided, we will not be able to assist you as a client in your matter. It is always optional to provide other personal data, however, should you not provide all the personal data relating to a matter, this might result in J. Zenonos not being able to provide you with a comprehensive and proper service.

5.2 Officers, employees and/or contractors of clients

5.2.1 Type of personal data

To enable us to engage and serve you as our client, we would need to collect some personal data of your officers, employees and/or contractors. This personal data may include the name, identity, position, address, contact details, business details, and data specified in the industry in which you may operate or conduct business. When we collect personal data, we also might need to make copies of your identification documents and passport or business certificates. During the time we render you with serves we may also collect other personal data as prescribed under Section 5.3 hereinunder. This personal data will be collected personally from yourself, alternatively via third parties of public sources.

5.2.2 Purpose of processing

Purpose of processing	Legal basis of processing
Providing legal and other professional service under our engagement letter and/or mandate and to attend to administrative tasks.	To perform within the legal mandate, terms of business, engagement letter with J. Zenonos, or to take any steps prior.
Compliance with laws and regulations.	Comply with legal obligations which J. Zenonos is subject.
To communicate with you as our client and to send you engagements about our firm.	To grow and develop our business in respect of services we can offer our client’s.

5.2.3 Recipients of personal data

In some instances, we may disclose your personal data to third parties providing J. Zenonos with administrative services, telecommunications, and any other service to support us in provide you with the service. We will always ensure that any third party will comply with our Privacy Notice in keeping your personal data safe. We may in some instances provide your personal data to law enforcement authorities.

5.2.4 Transfer of personal data

5.2.5 Retention of personal data

5.2.6 Requirement to provide personal data

It is mandatory to provide us with basic personal data. In the event of no basis personal data being provided we will not be able to assist you as a client in your matter. It is always optional to provide other personal data, however, should you not provide all the personal data relating to a matter, this might result in J. Zenonos not being able to provide you with a comprehensive and proper services.

5.3 Individuals involved or connected with client matters

During the time J. Zenonos attend to your matter, we may collect personal data of individuals who are involved and/or connected to your specific matter. These individuals may include the following but is not limited to, claimants, policyholders, witnesses, investigators, experts, advisors, consultants, vendors, and contractors.

5.3.1 Type of personal data

During the course of your matter J. Zenonos may need to collect personal data from individuals that is involved and connected in your matter. The type of personal data we collect will differ from matter to matter and the type of service we need to render. The personal data we would require may be collected from the person directly or from a third party or from any public sources which may include social media, company records, the Ariadni portal, and/or the Land Registry and/or the Companies Register.

5.3.2 Purpose of processing

Purpose of processing	Legal basis of processing
Providing legal and other professional service under our engagement letter and/or mandate and to attend to administrative tasks.	To perform within the legal mandate, terms of business, engagement letter with J. Zenonos, or to take any steps prior.
Compliance with laws and regulations.	Comply with legal obligations which J. Zenonos is subject.
To conduct investigations and analysis claims.	Necessary for legitimate interest and public interest in administering claims.

5.3.3 Recipients of personal data

In some instances, we may disclose your personal data to third parties providing J. Zenonos with administrative services, telecommunications, and any other service to support us in provide you with the service. We will always ensure that any third party will comply with our Privacy Notice in keeping your personal data safe. We may in some instances provide your personal data to legal counsel, investigators, experts, or translators, public authorities or registrars. The disclosure of your personal data will be to make enquiries and gathering of evidence in respect of your claim.

5.3.4 Transfer of personal data

5.3.5 Retention of personal data

5.3.6 Requirement to provide personal data

It is optional to provide most of the above personal data. However, in many cases, if you do not provide all the data, it may affect your participation in and rights in relation to the matter.

5.4 Partner, employee, service provider or contractor of J. Zenonos

We may process personal data about individuals who are partners, employees, service providers and contractors.

5.4.1 Type of personal data

J. Zenonos may collect your personal data, which will include your name, position, address, your contact details, areas of expertise, qualifications, and experience. Under some instances we may also by law obtain some personal data for identifying purposes. We may also be required to view or take a copy of your passport or identity documents. This information may be collected directly from you or through your firm.

5.4.2 Purpose of processing

Purpose of processing	Legal basis of processing
For the purpose of providing service to your firm and/or receiving services from your firm.	Legitimate interest in providing legal services and assistance to our clients.

5.4.3 Recipients of personal data

We may disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. We will always endure that such suppliers will adhere to our Privacy Notice. This disclosure may be for legal and non-legal services.

5.4.4 Transfer of personal data

Your data may be transferred abroad.

5.4.5 Retention of personal data

Your personal data will only be retained for as long as it has a legitimate purpose to do so, or as long as we are dealing with your matter, and we obtain service from other parties.

5.4.6 Requirement to provide personal data

You would need to provide us with the basic personal data of your firm in order for us to provide services. By only providing limited personal data may result in limited services being provided in your matter.

5.5 Subject – matter experts

J. Zenonos may process certain personal data about experts who assist or advise us in relation to a client matter. This may include doctors, psychologist, forensic experts and other subject matter experts.

5.5.1 Type of personal data

When we engage you as an expert, we will need to collect personal data about you which will include your name, position, address, contact details, business details, qualifications, experience and performance. This data may be obtained directly from you or from public.

5.5.2 Purpose of processing

Purpose of processing	Legal basis of processing
To provide your expert service as part of our legal and other professional services.	Necessary for the performance of your contract with us, or to take steps prior to entering into that contract.
To add you to our internal expert’s database.	Necessary for performance of the legitimate interest in providing legal and other services.
With consent we may disclose your details to some of our other client’s and other third parties to consider instructing you on those matters.	Your consent to the processing will be needed.

5.5.3 Recipients of personal data

5.5.4 Transfer of personal data

Your data may be transferred abroad.

5.5.5 Retention of personal data

Your personal data will only be retained for as long as it has a legitimate purpose to do so, or as long as we are dealing with you in a matter.

5.5.6 Requirement to provide personal data

You would need to provide us with the personal data, however if you do not provide the personal data it may affect your participation in and rights in relation to the matter.

5.6 Individual supplier(s)

J. Zenonos may process certain personal data about suppliers to us, who are individuals.

5.6.1 Type of personal data

To engage you as a supplier, we will need to collect personal data about you, including your name, position, address, contact details, business details, qualifications and experience.

5.6.2 Purpose of processing

Purpose of processing	Legal basis of processing
For allowing you to provide our office and for us to receiving your service for the related purpose.	Necessary for the performance of your contract with us, or to take steps prior to entering into the contract.

5.6.3 Recipients of personal data

We may disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. We will always ensure that such suppliers will adhere to our Privacy Notice. This disclosure may be for legal and non-legal services. With your consent we will also disclose your personal data to other J. Zenonos client’s.

5.6.4 Transfer of personal data

Your data may be transferred abroad.

5.6.5 Retention of personal data

Your personal data will only be retained for as long as it has a legitimate purpose to do so, or as long as we are dealing with you in a matter, or you are rendering a service to us.

5.6.6 Requirement to provide personal data

You would need to provide us with the personal data, however if you do not provide the personal data it may affect your participation in and rights in relation to the matter.

5.7 Advocate and/or Legal Counsel

J Zenonos may process certain personal data about Advocates and/or Legal Counsel, assisting J Zenonos in relation to a client matter.

5.7.1 Type of personal data

Upon our engagement with you as Advocate and/or Legal Counsel, we may collect personal data about you which may include your name, position, address, contact details, business details, qualifications, experience and performance. This data may be obtained directly from you or via third parties or public sources.

5.7.2 Purpose of processing

Purpose of processing

Legal basis of processing

In providing your professional services as part of our legal and professional services.

Adding your details to our database that might be viewed by other employees within J Zenonos.

Necessary to perform in terms of the contract.

Necessary to provide legal services to clients.

5.7.3 Recipients or categories of recipients

We may disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. We will always ensure that such suppliers will adhere to our Privacy Notice. In some circumstances we may be required and/or permitted by law to disclose your personal data for example to law enforcement authorities.

5.7.4 Transfers

Your data may be transferred abroad.

5.7.5 Retention period

Your personal data will only be retained for as long as it has a legitimate purpose to do so, or as long as you are assisting J Zenonos in the matter, or you are rendering a service to us.

5.7.6 Requirement to provide personal data

It is optional to provide most of the details mentioned above, however by not providing all the information may affect your participation in legal matters we would like to make use of your services.

5.8 Contacting us with a query

J. Zenonos may process certain personal data about you if you contact us with a query, by mail, email, fax or through our website.

5.8.1 Types of personal data

We may collect you name and contact details, and any other personal data you include in your communication to our office.

5.8.2 Purpose of processing

We will process your persona data to enable us to respond to your query.

Purpose of processing	Legal basis of processing
By contacting us with a query we see it as a freely given, specified and unambiguous indication that you want us to process your personal data.	Freely given.

5.8.3 Recipients of personal data

5.8.4 Transfers

Your data may be transferred abroad.

5.8.5 Retention period

Your personal data will only be retained for as long as it has a legitimate purpose to do so, or as long as we are dealing with you in a matter.

5.8.6 Requirement to provide personal data

You may choose what personal data you want to provide us with your query.

6. Legitimate Interest

As noted in Section 5 hereinabove, in some situations, J. Zenonos may process your personal data on the basis that it would be a legitimate interest. J. Zenonos provides a wide range of legal services, claim handling, and other professional legal services to its clients and furthermore has partners, employ employees, and engage contractors around the world.

J. Zenonos has a legitimate interest in:

Providing legal services (advice, litigation and advocacy), claims handling services (claim administration, management, and processing) and other professional legal services (corporate services, property services and transactions and immigration applications) to its clients and ensuring those services are of a high standard.
Understanding our clients’ needs and developing and growing high standard business relationships with our client’s and prospective ones.
Employing and managing its partners, employees, and contractors.
Complying with anti-money laundering.

J. Zenonos will only rely on our legitimate interest for the processing of your personal data where:

(a) the processing of your personal data is necessary for the purpose of the legitimate interest.

(b) the legitimate interest is not overridden by the data subject’s interests or fundamental rights and freedoms.

7. Transfer

As noted in Section 5 hereinabove, we may transfer your personal data to other countries. Our information system is hosted on a centrally located server. In the instance that we would need to obtain legal or any other professional advice from a service provider located in another country, we may need to transfer details in relation to such matter, which may include personal data. The regulations set out in the GDDP is followed in these instances and when we transfer personal data to non- EU countries then we follow localized regulations as to the protection of personal data. The following safeguards are adopted when we transfer personal data:

The transfer will be complaint with your home countries data protection laws.
When the data is transferred to any third party, they will be requested to: (i) to be used only for the purpose it was disclosed (ii) to make use of all technical and organizational measures to secure the data (iii) delete the data when it is no longer required (iv) always to threat the personal data in accordance with this Privacy Policy and local privacy data laws.

8. Automated Decision-making Including Profiling

J. Zenonos does not engage in any automated decision-making or profiling.

9. J. Zenonos Legal Platform and Tools

J. Zenonos Legal Platform is an inhouse automated legal system that is used, and measures using this system only have access according to their authority within J. Zenonos and all access is password protected.

10. Cookies

Our website uses cookies. You may mange your cookies in the footer of our website at any time. Cookies are tiny data files which are downloaded onto your device by the website which you are visiting to improve your experience, which is common practice with most professional websites. The next time you visit the same website, cookies ensure that your device is recognized. By using cookies and/or similar technologies, websites save information about the visits and its visitor. This information may include your internet protocol (IP) address, browser type, the device you may have used, Internet Services Provider (ISP), your clicking behavior, date and time stamp, referring/exit pages, such as specific web pages you might have visit. We use cookies to collect data on how visitors use our website. These cookies are completely anonymous and do not contain any personal data and we will seek your consent before we would store any cookies on your computer. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information. You will also have the right you refuse cookies, however this may affect the functionality you can access.

11. Your Rights

If you are located within an EU member state, you have certain rights in relation to your personal data as follows:

Access: You have the right to obtain access to and a copy of any personal data we hold about you. You also have the right to find out whether your personal data has been transferred outside the EU and any safeguards relating to this transfer.
Rectification: You have the right if you think the personal data, we hold of you are incorrect or incomplete to ask us to correct or complete that personal data.
Erasure: You have the right in certain circumstances to request erasure of your personal data.
Restriction of processing; You have the right in certain circumstances to request us not to process your person data for certain purposes.
Objection to processing: You have the right in certain circumstances to object in processing of your person data for certain purposes.
Data portability: You have the right in certain circumstances to request a copy of your personal data in a structured, commonly used and machine-readable format and manner. us not to process your person data for certain purposes.
Withdrawing consent: In the event of us processing your personal data due to you consent, you may at any stage withdraw your consent.

If you are located outside of an EU member state, you would still have rights in relation to your personal data under your local data protection laws. To carry out your right please contact our Data Protection Officer as mentioned in Section 3 hereinabove.