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Caspian Management's Privacy Policy
J.M. Caspian Management Limited (‘Caspian Management’) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we treat your personal data and further inform you about your privacy rights and how the provisions of the General Data Protection Regulation (EU) 2016/679 (the ‘GDPR’) protect you.
Caspian Management may collect information that you choose to provide in communications with us. Please do not send us confidential information until we have confirmed in writing that we represent or act for you or your company or organisation. Unsolicited emails from non-clients do not establish a client relationship. Your privacy is very important to us and we are committed in protecting your personal data in accordance with GDPR and the Processing of Personal Data (Protection of Individuals) Law 125(I)/2018 (‘DPL’) as amended from time to time.
We follow strict security procedures in the storage and disclosure of personal information that you are providing to us to protect your privacy.
In this section you can find information about our policy regarding the protection of personal data and security policy that we follow.
This website is owned and operated by J. M Caspian Management Limited (‘Caspian Management’, ‘we’ or ‘us’) which is a limited liability company incorporated in Cyprus under registration number HE 437643 and its registered office at Agias Marinas 1, Agias Zoni 3026, Limassol, Cyprus, operating through a number of separately constituted and regulated legal entities which provide legal and other ancillary services in accordance with the relevant laws of the Republic of Cyprus.
Caspian Management is a data controller responsible for your personal information processed via the website, www.caspian-management.com (the ‘Website’). If you have any questions about this Privacy Statement or any requests regarding your legal rights. The e-mail address is info@caspian-management.com and the postal address is Agias Marinas 1, Agias Zoni 3026, Limassol, Cyprus.
Personal data that we collect may include the full name, passport or identity card number, residential and business addresses, date of birth, occupation, nationality, e-mail addresses, telephone numbers and CV information. Additionally, as per the applicable Anti-Money Laundering rules and regulations (“AML”), we may also collect information as to source of funds, expected annual turnover, bank accounts, marital status, US Foreign Account Tax Compliance Act (“FATCA”), Common Reporting Standard (“CRS”) information, tax information and nature of transactions.
The personal data may be provided either directly by you or from authorised third party introducers to whom you have given the express authority to disclose this data to us.
Personal data may also be obtained from public sources such as public registers, internet searches, news articles and sanction lists.
Before entering into any business relationship with you as our client we are obliged to collect your personal data and perform due diligence checks in relation to the services we will be providing to you. Caspian Management is regulated and supervised by the Cyprus Bar Association and (‘CyBar’) subject to the provision of the AML law and regulations and the regulations and directives of CyBar and we can only enter into a contractual relationship with you subject to being provided with your personal data and all other Know Your Client information and documentation.
We process personal data for:
(a) Meeting our contractual commitments to you and providing you with our professional services
(b) Adhering to any of your written requests and/or consents for disclosure
(c) Adhering to our legitimate interests or legal obligations including reporting obligations
(d) Complying with other reporting requirements (such as FATCA and CRS) and any other European of Cyprus legislative requirements
(e) Complying with AML and CyBar legal and regulatory obligations
(f) Disclosing when necessary to the relevant tax authorities, auditors, accountants, tax advisors and banks for providing their respective services to you and to Caspian Management
(g) Sending you updates regarding laws and regulations or regarding Caspian Management
(h) Administering, maintaining and ensuring the security of our information systems, application and website
In the course of performance of our contractual and statutory obligations your personal data is shared between the team members of Caspian Management and/or third parties providing services to Caspian Management for the purpose and in the context of providing our services. Such third-party service providers enter into contractual agreements with us for observing confidentiality according to the DPL and the GDPR.
We only share personal data with trusted third parties who are contractually bound to protect the data we entrust them with, and the third-parties recipients are limited to the following:
(a) Other advisors of the clients such as their tax advisors, auditors, lawyers and insurers
(b) Parties that support Caspian Management in the provision of its services such as IT system support, document protection services and cloud-based software services and mailroom support
(c) Caspian Management professional advisers, including auditors, insurers and lawyers
(d) A potential buyer or transferee of all of part of the business of Caspian Management and their advisers
(e) Promoting your best interests
Our website uses cookies in order to make it improve the services we offer. Where cookies are used, a statement will be sent to your browser notifying you of the use of cookies. You can reject the cookies, but this will affect your ability to use our website. If you accept the cookies the website may automatically collect information as you browse.
We will hold your Personal Information securely in line with physical, technical and administrative security measures. However, the transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted, and any transmission is at your own risk.
We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your Personal Information from unauthorised access and disclosure. For example, only authorised employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we have trained our employees on how to handle, manage and process Personal Information, applied upgraded technical measures and transformed our policies and procedures in a way that will comply with the GDPR.
Users should also take care with how they handle and disclose their Personal Information and should avoid sending Personal Information through insecure email. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
Caspian Management retains your personal data for as long as you are its client and the data is required for complying with its professional commitments and for satisfying any legal, accounting or reporting requirements and where a specific legal, regulatory or contractual requirement and obligation applies. You have the right to request that we delete your data subject to no legal or regulatory restriction to do so. We will dispose of your personal data in a secure manner.
Under the GDPR and DPL you have the following rights in relation to your personal data:
(a) Access Request: anytime you may request to receive a copy of the Personal data Caspian Management holds for you
(b) Request Correction (Rectification): this right gives you the opportunity to make corrections or update any incomplete information.
(c) Request Erasure: this right allows you to request from us to delete any personal data concerning you and you think there is no good reason to process it, unless otherwise required by any legislation.
(d) Object to Process: this gives you the right to object to the processing of your personal data (this is subject to the legal basis on which the processing activity is based)
(e) Request Restriction: with this right you will be able to request from us to restrict the processing of your personal data in certain situations, such as when your personal data is not accurate or is used by Caspian Management unlawfully or it is not relevant anymore but you want Caspian Management to keep it
(f) Withdraw your consent regarding the processing of your personal data: this consent can be withdrawn by you at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing which was based on consent before it was withdrawn or revoked by you.
(g) Right of portability: you may request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party where this is technically possible.
The above rights are subject to restrictions as laid down by the applicable law, this Privacy Statement and any written agreement that you enter into with Caspian Management.
If you wish to exercise any of these rights set out above please contact us at the e-mail indicated above and we will respond to you within one month. In case more time will be required we will be informing you accordingly. We may request proof of identification to verify your request. We have the right to refuse your request where the law permits us to do so or if your request is manifestly unfounded or excessive or against public interest.
If you consider that the processing of your personal data infringes the General Data Protection Regulation (Regulations (EU) 2016/2017) you have the right to lodge a complaint with the Data Protection Authority in the European Member State of your residence, place of work or place of an alleged infringement. The Data Protection Authority in Cyprus is the Commissioner for Personal Data Protection and you may contact the said Authority via the following link: www.dataprotection.gov.cy.
Caspian Management may amend this Privacy Policy from time to time. In case of changes, we will amend the revision date at the top of the page and notify you accordingly by a prominent notice on our website or by sending you a private notification.
