Data Privacy Policy

Last updated: 23rd of May, 2018

This Data Privacy Policy applies to Personal Data processed by our Firm as a controller and processor, in accordance with the EU General Data Protection Regulation 2016/679 (GDPR) (as may be amended or supplemented from time to time) (hereinafter the “GDPR”) and in line with best practices applied.

Protection of your personal data

Our Firm is committed to protecting your Personal Data and to achieving the best means of processing it in a fair and transparent manner.

We continuously reinforce our standards of technology, managerial measures and operational security, to ensure maximum protection of your Personal Data. Such measures include applying robust technical controls and procedures to restrict access as required as well as physical security measures by maintaining data at appropriately secured locations, and ensuring all our staff is educated and well-trained with regards to our privacy obligations, handling of Personal Data in strict confidence and applying appropriate measures when processing such data.

Personal data processed

Personal Data means any information about an individual from which such individual may be identified. Personal Data we process may include data grouped under the following indicative headings:

We do not process Sensitive Personal Data including details on religion, sexual orientation, political opinions, etc.

How personal data processed

In the provision of our services, our Firm processes Personal Data collected / received from a range of sources e.g. from:

How we process personal data and legal basis for such processing

In the provision of our services, our Firm processes Personal Data collected / received from a range of sources e.g. from:

as may be required from time to time, for legitimate purposes and in the context of the carrying out of our professional activities / services.
We will only process Personal Data within the parameters permitted by law, which will most commonly include the following reasons:
As the protection of your Personal Data is of utmost importance for our Firm we make sure at all times to give careful consideration to and assess all legitimate interests that arise (including our legitimate interests, those of third parties and those of the data subject), against the data subject’s rights and potential impact thereon.

We may process Personal Data on more than one lawful ground, depending on the specific purpose for which we are using such data. Please contact us (at for details about the specific legal ground(s) we are relying on in processing your Personal Data, should you wish to do so.

How long will we retain personal data for

Personal Data shall be retained for:

In determining the appropriate retention period, our Firm gives careful consideration to applicable legal and regulatory requirements, the amount, nature and sensitivity of the data in question, potential risk of harm from unauthorized use or disclosure, and whether we could achieve the purposes at hand through other means.

Disclosure/ transfer of personal data

In achieving the legitimate purposes for processing of Personal Data, we may have to share it with other parties which shall also act as processors or joint controllers of such Personal Data, e.g.:

Internal Third Parties
External Third Parties
We require all such parties to respect the security of your Personal Data and to treat it in accordance with the law.

Where such data is transferred to countries or territories outside the European Economic Area (not recognised by the European Commission as offering an adequate level of data protection), our Firm will ensure that appropriate data transfer mechanisms (as required) are put into place, such as EU Standard Contractual Clauses, to ensure protection of your Personal Data.

Data subject's legal right

Your Rights

Your rights are listed below and may be exercised to the extent permitted under the GDPR, in line and within the parameters of the legal and regulatory framework within which we – as a licensed Accounting and Administrative Services firm – operate, and in accordance with our Data Privacy Policy (as may be revised and communicated to you from time to time):

Your rights may be exercised by contacting:

Such requests shall not affect the lawfulness of any processing carried out before the exercise of your rights.

If, despite our commitment and continuous efforts to protect your data you feel that your data protection rights are not being adequately safeguarded, you may lodge an official complaint with the Data Protection Commissioner:

What We Need From You
It is important that all Personal Data we maintain on you remains accurate and current at all times. Please keep us informed if any of your Personal Data changes during your relationship with us.

Time Limit to Respond
We will try to respond to all legitimate requests within one month, depending on the complexity and number of requests.

Change to a data privacy policy and related matters

Please be advised that the Data Privacy Policy shall be subject to periodic review; any modifications / changes, drafted in line with and within the parameters of the GDPR and other applicable laws, will be included on our Firm’s website:

Any modifications / changes and shall be effective as of the date of revision.

We thus encourage you to periodically review the Data Privacy Policy from time to time so as to remain informed about how we are protecting Personal Data.

Please note that the Data Privacy Policy supplements any other notices given to you from time to time, and is not intended to override them. This policy should always be read alongside other relevant Terms and Conditions such as Engagement Letters signed with our Firm, regulating services provided by us..

This is the latest version of the Data Privacy Policy.

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