LEGAL
Privacy Policy
1. General
1.1 This is the Privacy Policy of PRIMEROCK Ltd, a company registered in Cyprus under registration number HE 428303 which provides corporate services in accordance with the relevant laws of the Republic of Cyprus.
2. Scope of the Privacy Policy
2.1 With the implementation of the Privacy Policy the Company aims to outline the Company’s responsibility to manage and ensure the protection of privacy and the clients’ personal and financial information and to behave in a fair and moral manner concerning the gathering, storing and handling of data. This process will be carried out with transparency and respect towards the rights of individuals who entrust it with their information.
The clients’ privacy is considered and treated by Company with utmost importance and highest priority and this Policy applies to former, existing and potential clients as well as to any visitors of the Company’s website.
2.2 For the purpose of this Privacy Policy, Data Protection Legislation means:
(i) the General Data Protection Regulation 2016/679 (the “GDPR”) applicable in the European Union, including Cyprus until any Cyprus data protection legislation replaces or adopts the GDPR in Cyprus and
(ii) then such Cyprus data protection legislation replacing the GDPR once in force and applicable.
For the purpose of the Data Protection Legislation, the data controller is PRIMEROCK Ltd.
2.3 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The clients’ privacy is considered and treated by Company with utmost importance and highest priority and this Policy applies to former, existing and potential clients as well as to any visitors of the Company’s website.
2.2 For the purpose of this Privacy Policy, Data Protection Legislation means:
(i) the General Data Protection Regulation 2016/679 (the “GDPR”) applicable in the European Union, including Cyprus until any Cyprus data protection legislation replaces or adopts the GDPR in Cyprus and
(ii) then such Cyprus data protection legislation replacing the GDPR once in force and applicable.
For the purpose of the Data Protection Legislation, the data controller is PRIMEROCK Ltd.
2.3 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
3. Consent
3.1 By using (collectively, “Using” or “Use”) our Website, registering with us or submitting information to us you consent and agree with the terms of this Policy and you hereby consent to the collect, process, storage, use and disclosure of your personal data by the Company whether such use is by the Company or by another third party which may be required by them in order to effectively perform Services in connection with the Company’s Terms and Conditions or effectively execute any related operational function performed by the Company to its Clients in accordance with this Policy and as explained below herein. If you do not agree with this Privacy Policy, you must not use our Website, access our services or submit information to us.
4. Personal Information / Data We May Collect (or Receive) About You
4.1 The Company will only use clients’ personal data in accordance with international data protection practices. In particular, the Company is registered as a Data Controller with the Office of the Commissioner for Personal Data Protection and will collect, process, maintain, store, use and handle clients’ personal information in accordance with the Processing of Personal Data (Protection of the Individual) Law of 138(1) 2001 and General Data Protection Regulation (2018) as amended from time to time (the “Law”) this Privacy Policy.
4.2 During the provision of the information online, clients are required to provide personal information. In the event the client intends to deposit money to the Company’s account using his payment card, in accordance with the recommendations of Payment Card Industry Security Standard Council, customer card details are protected using Transport Layer encryption – TLS 1.2 and application layer with algorithm AES and key length 256 bit.
4.3 We may collect such Personal Information from other persons including, for example, credit reference agencies, fraud prevention agencies, banks, other financial institutions, third authentication service providers and the providers of public registers.
4.4 “Personally identifiable information” (or “Personal Information”) means any information that may be used, either alone or in combination with other information, to personally identify, contact or locate any Customer of the Company (referred to as “User”).
4.5 Categories of Personal Information we collect and use on or through our Website include:
4.2 During the provision of the information online, clients are required to provide personal information. In the event the client intends to deposit money to the Company’s account using his payment card, in accordance with the recommendations of Payment Card Industry Security Standard Council, customer card details are protected using Transport Layer encryption – TLS 1.2 and application layer with algorithm AES and key length 256 bit.
4.3 We may collect such Personal Information from other persons including, for example, credit reference agencies, fraud prevention agencies, banks, other financial institutions, third authentication service providers and the providers of public registers.
4.4 “Personally identifiable information” (or “Personal Information”) means any information that may be used, either alone or in combination with other information, to personally identify, contact or locate any Customer of the Company (referred to as “User”).
4.5 Categories of Personal Information we collect and use on or through our Website include:
- Information that you provide by filling in forms, in particular at the time of first contact with us.
- We also collect Personal Information when you report a problem with our Website.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
- Details of transactions you carry out, if any, and of the fulfilment of your orders as well as for the provision of our services.
5. How We Collect Your Personal Data
5.1 We may collect (or receive) and process your personal data when:
a. You contact us, whether through our Website, our Apps or otherwise (for example, via our online form, by e-mail, post, fax or phone), as we may keep a record of that correspondence. For example, if you submit a complaint, report a problem with our services or our Websites or our Apps or otherwise liaise with our customer service, technical support or any other department in our company. This includes information provided by you when you update a customer account such as your name, e-mail, country, password, etc;
b. We ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
c. You use and interact with our Website or our Apps including your device’s manufacturer and model, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system, web browser, platform, mobile carrier, and your ISP. We may collect details of your visits to our Website or our Apps (including, but not limited to, traffic data, location data, weblogs and other communication data). We do this via email and website cookies, and similar tracking technology built into our Websites and Apps. We make cookie policies available on each of our Websites and Apps to give you more detailed information on how we use them;
d. You use social media, including “like” buttons and similar functions made available by social media platforms.
a. You contact us, whether through our Website, our Apps or otherwise (for example, via our online form, by e-mail, post, fax or phone), as we may keep a record of that correspondence. For example, if you submit a complaint, report a problem with our services or our Websites or our Apps or otherwise liaise with our customer service, technical support or any other department in our company. This includes information provided by you when you update a customer account such as your name, e-mail, country, password, etc;
b. We ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
c. You use and interact with our Website or our Apps including your device’s manufacturer and model, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system, web browser, platform, mobile carrier, and your ISP. We may collect details of your visits to our Website or our Apps (including, but not limited to, traffic data, location data, weblogs and other communication data). We do this via email and website cookies, and similar tracking technology built into our Websites and Apps. We make cookie policies available on each of our Websites and Apps to give you more detailed information on how we use them;
d. You use social media, including “like” buttons and similar functions made available by social media platforms.
6. Use of Personal Information/Data
6.1 The collection of personal Information (not in the public domain or already possessed by us without a duty of confidentiality) which we hold is to be treated by us as confidential and will not be used for any purpose other than in connection with the provision, administration and improvement of our Services to you or the furthering of our Agreement between us, establishing a relationship between us, reviewing your ongoing needs, enhancing customer service and products, giving you ongoing information or opportunities that we believe may be relevant to you, improving our relationship, anti-money laundering and due diligence checks, for research and statistical purposes and for marketing purposes (according to the Agreement between us and as described in this Privacy Policy), as applicable.
We will use your personal information for the purposes of providing the services you have requested, for administration and customer services, for credit scoring, for marketing, for research/statistical analysis purposes and to ensure that the content, services and advertising that we offer are tailored to your needs and interests. We may keep your information for a reasonable period for these purposes. We may need to share your information with our service providers and agents for these purposes.
In assessing your application to open an account, to prevent fraud, to check your identity and to prevent money laundering, we may search the files of credit reference agencies that will record any credit searches on your file. The information will be used by other credit grantors for making credit decisions about you and the people with whom you are financially associated, for fraud prevention, money laundering prevention and occasionally for tracing debtors. Information used for these purposes will include publicly available information such as electoral roll, county court judgments, bankruptcy orders or repossessions.
6.2 In order for the Company to provide, monitor and improve the quality service and security to its clients, the Company may use the clients’ personal information/data for one or more of the following purposes:
a. Verify the identity of clients;
b. To maintain clients’ personal profile;
c. Assess and improve the products and services provided to clients;
d. To such an extent as reasonably required so as to execute Orders and for purposes ancillary to the provision of the Services;
e. Company’s transmission/execution and post transaction/order services;
f. Assess and improve clients’ browsing experience;
g. Analysis of statistical data which will aid the Company to provide clients with better suited products and services in the future;
h. To pass clients’ personal information/data to third parties for marketing purposes without prior written consent;
i. To the Company’s professional advisors provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well;
j. To other service providers who create, maintain or process databases (whether electronic or not), offer record keeping services, email transmission services, messaging services or similar services which aim to assist the Company collect, storage, process and use Client information or get in touch with the Client or improve the provision of the Services under this Agreement;
k. To a Trade Repository or similar under the Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central
l. Counterparties (CCPs) and trade repositories (TRs) (EMIR);
m. To other service providers for statistical purposes in order to improve the Company’s marketing, in such a case the data will be provided in an aggregate form;
n. To an Affiliate of the Company or any other company in the same group of the Company;
o. To market research call centers that provide telephone or email surveys with the purpose to improve the services of the Company, in such a case only the contact details the data will be provided;
p. Inform clients of additional products, services or promotions relevant to its clients.
6.3 In regards to point (o) above and should for any reason clients do not consent to receive information of this nature, the client can inform us accordingly by contacting the Company on the contact details provided by the Company on its Terms and Conditions at the following address: hello@primerock.eu.
6.4 We may disclose personal data in order to comply with a legal or regulatory obligation.
6.5 We may contact you by mail, telephone, fax, e-mail or other electronic messaging service with offers of services or information that may be of interest to you. By providing us with your fax number, telephone numbers or email address you consent to being contacted by these methods for these purposes. If you do not wish to receive marketing information from us, please inform us accordingly.
6.6 Any information, which we send to you by email, will not be encrypted. We cannot guarantee confidentiality of emails that you send to us.
6.7 You may ask us to provide you with information about our services or about services offered jointly with or on behalf of other organisations by sending us an email to hello@primerock.eu.
You have the following Rights: The right to be informed The right of access
The right to rectification The right to erasure
The right to restrict processing The right to data portability The right to object
Rights in relation to automated decision making and profiling
Right to Withdraw Consent
Those whose Personal Data we keep refer have the right at any time to obtain confirmation of the existence of the same from the Data Controller, to know the content and origin, to check its accuracy or request its integration, deleting, updating, rectification, erasure, anonymisation or blocking of Personal Data processed in violation of law, and to oppose in any case, for legitimate reasons, to their treatment.
To make a request, please contact us, verifying your identity and specifying what information you require. We may charge an administrative fee.
Data controller and Data processor: PRIMEROCK Ltd*
We may authorize another natural person, legal person, public administration or any other body, association or organization authorized to process the Personal Data in compliance with this Privacy Policy, on its behalf.
PRIMEROCK Ltd does not provide any services to children, nor processes any personal data in relation to children, where ‘children’ are individuals who are under the age of eighteen (18).
We will use your personal information for the purposes of providing the services you have requested, for administration and customer services, for credit scoring, for marketing, for research/statistical analysis purposes and to ensure that the content, services and advertising that we offer are tailored to your needs and interests. We may keep your information for a reasonable period for these purposes. We may need to share your information with our service providers and agents for these purposes.
In assessing your application to open an account, to prevent fraud, to check your identity and to prevent money laundering, we may search the files of credit reference agencies that will record any credit searches on your file. The information will be used by other credit grantors for making credit decisions about you and the people with whom you are financially associated, for fraud prevention, money laundering prevention and occasionally for tracing debtors. Information used for these purposes will include publicly available information such as electoral roll, county court judgments, bankruptcy orders or repossessions.
6.2 In order for the Company to provide, monitor and improve the quality service and security to its clients, the Company may use the clients’ personal information/data for one or more of the following purposes:
a. Verify the identity of clients;
b. To maintain clients’ personal profile;
c. Assess and improve the products and services provided to clients;
d. To such an extent as reasonably required so as to execute Orders and for purposes ancillary to the provision of the Services;
e. Company’s transmission/execution and post transaction/order services;
f. Assess and improve clients’ browsing experience;
g. Analysis of statistical data which will aid the Company to provide clients with better suited products and services in the future;
h. To pass clients’ personal information/data to third parties for marketing purposes without prior written consent;
i. To the Company’s professional advisors provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well;
j. To other service providers who create, maintain or process databases (whether electronic or not), offer record keeping services, email transmission services, messaging services or similar services which aim to assist the Company collect, storage, process and use Client information or get in touch with the Client or improve the provision of the Services under this Agreement;
k. To a Trade Repository or similar under the Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central
l. Counterparties (CCPs) and trade repositories (TRs) (EMIR);
m. To other service providers for statistical purposes in order to improve the Company’s marketing, in such a case the data will be provided in an aggregate form;
n. To an Affiliate of the Company or any other company in the same group of the Company;
o. To market research call centers that provide telephone or email surveys with the purpose to improve the services of the Company, in such a case only the contact details the data will be provided;
p. Inform clients of additional products, services or promotions relevant to its clients.
6.3 In regards to point (o) above and should for any reason clients do not consent to receive information of this nature, the client can inform us accordingly by contacting the Company on the contact details provided by the Company on its Terms and Conditions at the following address: hello@primerock.eu.
6.4 We may disclose personal data in order to comply with a legal or regulatory obligation.
6.5 We may contact you by mail, telephone, fax, e-mail or other electronic messaging service with offers of services or information that may be of interest to you. By providing us with your fax number, telephone numbers or email address you consent to being contacted by these methods for these purposes. If you do not wish to receive marketing information from us, please inform us accordingly.
6.6 Any information, which we send to you by email, will not be encrypted. We cannot guarantee confidentiality of emails that you send to us.
6.7 You may ask us to provide you with information about our services or about services offered jointly with or on behalf of other organisations by sending us an email to hello@primerock.eu.
You have the following Rights: The right to be informed The right of access
The right to rectification The right to erasure
The right to restrict processing The right to data portability The right to object
Rights in relation to automated decision making and profiling
Right to Withdraw Consent
Those whose Personal Data we keep refer have the right at any time to obtain confirmation of the existence of the same from the Data Controller, to know the content and origin, to check its accuracy or request its integration, deleting, updating, rectification, erasure, anonymisation or blocking of Personal Data processed in violation of law, and to oppose in any case, for legitimate reasons, to their treatment.
To make a request, please contact us, verifying your identity and specifying what information you require. We may charge an administrative fee.
Data controller and Data processor: PRIMEROCK Ltd*
We may authorize another natural person, legal person, public administration or any other body, association or organization authorized to process the Personal Data in compliance with this Privacy Policy, on its behalf.
PRIMEROCK Ltd does not provide any services to children, nor processes any personal data in relation to children, where ‘children’ are individuals who are under the age of eighteen (18).
7. Storage of Personal Data
7.1 We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. We retain personal data for as long as we have a legitimate business purpose to do so and where a specific legal, regulatory or contractual requirement applies. We will dispose of personal data in a secure manner when we no longer need it.
8. Protection and Security of Personal information/Data
8.1 The Company takes reasonable precautions to protect personal information/data from loss, theft, misuse, unauthorized access or disclosure, alteration, or destruction. The Company employs physical, electronic, and procedural safeguards to protect personal information/data and it does not store personal information/data for longer than necessary for the provision of services or as permitted by law.
8.2 The Company’s datacenter(s) contain both internal and external servers. Access to the Company’s internal server is restricted to authorised personnel (i.e. employees and authorised service providers), servers and locations; our external servers can be accessed via the Internet. Any personal information/data provided by clients to the Company will be strictly protected under enhanced measures of security, protected against loss, misuse, unauthorized access or disclosure, alteration, or destruction with use various security measures such as encryption during data transmission, strong authentication mechanisms and separation of machines and data to provide secure areas in order to protect clients’ personal information from unauthorised users and such personal information will be treated as confidential and shared only with the Company and its affiliates and/or authorised service providers and shall not be disclosed to any third parties except, and without notice, in accordance with the provisions of this Policy as well as under any regulatory or legal proceedings.
8.3 We will use reasonable endeavours to implement appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. For instance, our security measures include, but are not limited to:
a. educating our employees as to their obligations with regard to your personal data;
b. requiring our employees to use passwords and two-factor authentication when accessing our systems;
c. encrypting data sent from your computer to our systems during internet transactions and client access codes transmitted across networks;
d. employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses entering our systems;
e. using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
f. practicing a clean desk policy in all premises occupied by us and our related bodies corporate and providing secure storage for physical records; and
g. employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorised access to buildings.
8.4 We will ensure that your information will not be disclosed to government institutions or authorities except if required by law (e.g. when requested by regulatory bodies or law enforcement organisations in accordance with applicable legislation).
8.5 Certain services may include social networking, chat room or forum features. When using these features please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users.
8.2 The Company’s datacenter(s) contain both internal and external servers. Access to the Company’s internal server is restricted to authorised personnel (i.e. employees and authorised service providers), servers and locations; our external servers can be accessed via the Internet. Any personal information/data provided by clients to the Company will be strictly protected under enhanced measures of security, protected against loss, misuse, unauthorized access or disclosure, alteration, or destruction with use various security measures such as encryption during data transmission, strong authentication mechanisms and separation of machines and data to provide secure areas in order to protect clients’ personal information from unauthorised users and such personal information will be treated as confidential and shared only with the Company and its affiliates and/or authorised service providers and shall not be disclosed to any third parties except, and without notice, in accordance with the provisions of this Policy as well as under any regulatory or legal proceedings.
8.3 We will use reasonable endeavours to implement appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. For instance, our security measures include, but are not limited to:
a. educating our employees as to their obligations with regard to your personal data;
b. requiring our employees to use passwords and two-factor authentication when accessing our systems;
c. encrypting data sent from your computer to our systems during internet transactions and client access codes transmitted across networks;
d. employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses entering our systems;
e. using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
f. practicing a clean desk policy in all premises occupied by us and our related bodies corporate and providing secure storage for physical records; and
g. employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorised access to buildings.
8.4 We will ensure that your information will not be disclosed to government institutions or authorities except if required by law (e.g. when requested by regulatory bodies or law enforcement organisations in accordance with applicable legislation).
8.5 Certain services may include social networking, chat room or forum features. When using these features please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users.
9. Changes in Personal information/Data
9.1 Under the Agreement between us, we have the right to disclose your information (including recordings and documents of a confidential nature, card details) in certain circumstances.
According to the Agreement between us, Your Information may be disclosed:
a. To protect the Company’s rights and/or to comply with judicial proceedings and/or court order;
b. To protect and defend the rights or property of the Company’s website;
c. To protect the safety of Company’s clients, all users of the Company’s website and/or the public.
d. Where required by law or a court order by a competent Court;
e. Where requested by the Cyprus Securities and Exchange Commission or any other regulatory authority having control or jurisdiction over the Company or the Client or their associates or in whose territory the Company has clients;
f. regulatory authority having control or jurisdiction over the Company or the Client or their associates or in whose territory the Company has Clients;
g. To relevant authorities to investigate or prevent fraud, money laundering or other illegal activity;
h. To credit reference and fraud prevention agencies, third authentication service providers, banks and other financial institutions for credit checking, fraud prevention, anti-money laundering purposes, identification or due diligence checks of the Client. To do so they may check the details the Client supplied against any particulars on any database (public or otherwise) to which they have access. They may also use Client details in the future to assist other companies for verification purposes. A record of the search will be retained by the Company;
i. Where necessary in order for the Company to defend or exercise its legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority;
j. At the Client’s request or with the Client’s consent;
k. To successors or assignees or transferees or buyers, with ten Business Days prior Written Notice to the Client;
10. Your Rights in Relation to Your Personal Data
10.1 The Company may, from time to time, combine clients’ personal information/data with information from other users of the Company’s website in order to create impersonalized statistical data. The Company may provide this statistical data to Third Parties solely for statistical purposes and in an effort to better improve the Company’s marketing campaign.
The Company will take all reasonable measures in order to ensure that in no circumstances clients will be identifiable from this statistical data and consequently for clients to remain anonymous.
The Company will take all reasonable measures in order to ensure that in no circumstances clients will be identifiable from this statistical data and consequently for clients to remain anonymous.
11. Retention of Personal Data
11.1 Please note that these rights do not apply in all circumstances. You are entitled to:
a. request access to your personal data (commonly known as a “data subject access request”);
b. request correction of the personal data that we hold about you;
c. request erasure of your personal data. 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;
d. object to 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 ground 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;
e. 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:
i. if you want us to establish the data’s accuracy;
ii. where our use of the data is unlawful but you do not want us to erase it;
iii. 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; or
iv. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
f. request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information (i.e. not to hard copies) which you initially provided consent for us to use or where we used the information to perform a contract with you; and
g. withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please email us at hello@primerock.eu.
11.2 Please quote your name and address. We should be grateful if you would also provide brief details of the data that you would like a copy of or which you would like to be corrected (this helps us to more readily locate your data).
11.3 We will require proof of your identity before providing you with details of any personal data we may hold about you.
11.4 We try to respond to all legitimate requests within 48 hours. Occasionally, it may take us longer than 48 hours if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 2 hours of the receipt of your request and keep you updated.
11.5 We may charge you a reasonable fee to you when a request is manifestly unfounded, excessive or repetitive, or we receive a request to provide further copies of the same data. Alternatively, we may refuse to comply with your request in these circumstances.
a. request access to your personal data (commonly known as a “data subject access request”);
b. request correction of the personal data that we hold about you;
c. request erasure of your personal data. 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;
d. object to 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 ground 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;
e. 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:
i. if you want us to establish the data’s accuracy;
ii. where our use of the data is unlawful but you do not want us to erase it;
iii. 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; or
iv. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
f. request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information (i.e. not to hard copies) which you initially provided consent for us to use or where we used the information to perform a contract with you; and
g. withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please email us at hello@primerock.eu.
11.2 Please quote your name and address. We should be grateful if you would also provide brief details of the data that you would like a copy of or which you would like to be corrected (this helps us to more readily locate your data).
11.3 We will require proof of your identity before providing you with details of any personal data we may hold about you.
11.4 We try to respond to all legitimate requests within 48 hours. Occasionally, it may take us longer than 48 hours if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 2 hours of the receipt of your request and keep you updated.
11.5 We may charge you a reasonable fee to you when a request is manifestly unfounded, excessive or repetitive, or we receive a request to provide further copies of the same data. Alternatively, we may refuse to comply with your request in these circumstances.
12. Use of cookies
8.1 The Company may use cookies to assess and improve the performance of the website and its products and services offered to its clients. Cookies are used by most internet browsers and are small pieces of information which use a unique identification tag and are stored on clients’ device as a result of clients using the Company’s website or other services the Company provides to its clients.
8.2 Clients may be able to refuse to have cookies stored on their device they may be able to change the setting of their browser to refuse all cookies, and/or have their device to notify them each time a cookie is sent to their device. By controlling their cookies in this way may impair the quality of service provided by the Company to its clients and therefore, it is recommended for clients to allow cookies on their device to ensure the best possible experience and quality services provided by the Company.
8.4 PRIMEROCK Ltd’s (“we”, “our”, “us”) website uses cookies.
8.2 Clients may be able to refuse to have cookies stored on their device they may be able to change the setting of their browser to refuse all cookies, and/or have their device to notify them each time a cookie is sent to their device. By controlling their cookies in this way may impair the quality of service provided by the Company to its clients and therefore, it is recommended for clients to allow cookies on their device to ensure the best possible experience and quality services provided by the Company.
8.3 For more information about cookies, clients may refer to the Company’s “Cookie Policy” available on the Company’s website.
8.4 PRIMEROCK Ltd’s (“we”, “our”, “us”) website uses cookies.
13. Contact Clients/Recordings
13.1 For quality assurance purposes any type of communication between the clients and the Company whether in writing, email or by telephone or other means of medium shall be monitored and recorded by the Company without any prior warning (unless required to do so by the applicable rules and regulations). Clients acknowledge and accept that such recordings are the sole property of the Company. Clients further accept that such recordings constitute conclusive evidence of the Orders/Instructions/Requests or conversations so recorded.
13.2. Any person who wishes not to be contacted further by telephone, email or other means of medium, can inform the Company accordingly by contacting the Company on the contact details provided by the Company the following address: hello@primerock.eu.
13.2. Any person who wishes not to be contacted further by telephone, email or other means of medium, can inform the Company accordingly by contacting the Company on the contact details provided by the Company the following address: hello@primerock.eu.
14. Clients Rights
14.1 Clients have no obligation to provide any of the personal information/data requested by the Company. In this case, the Company reserves the right to reject to provide clients with any other services, information or assistance.
14.2 Under the Law, clients have the right to request any personal information/data the Company holds about the clients and to inform the Company of any perceived inaccuracy. Clients acknowledge and accept that the Company may a charge fee to cover the associated administrative costs.
14.3 In case any of the clients’ personal information have changed at any given time or they wish from the Company to delete any personal data, they may do so by informing the Company via email at hello@primerock.eu. The Company to the extent permitted by law including those cases where the Company is required to hold clients’ personal data for regulatory and legal purposes for the provision of services and/or maintenance of adequate business records, will proceed with changing or deleting clients’ personal data in accordance with the instructions received.
14.2 Under the Law, clients have the right to request any personal information/data the Company holds about the clients and to inform the Company of any perceived inaccuracy. Clients acknowledge and accept that the Company may a charge fee to cover the associated administrative costs.
14.3 In case any of the clients’ personal information have changed at any given time or they wish from the Company to delete any personal data, they may do so by informing the Company via email at hello@primerock.eu. The Company to the extent permitted by law including those cases where the Company is required to hold clients’ personal data for regulatory and legal purposes for the provision of services and/or maintenance of adequate business records, will proceed with changing or deleting clients’ personal data in accordance with the instructions received.
15. Amendment/Review of the Policy
16. How to Make a Complaint
16.1 If you have a complaint about the way in which your personal data is being processed, please email hello@primerock.eu. In the event that you are not satisfied with our handling of your complaint, you have the right to report your concern to
the
Information Commissioner
1, Iasonos Street, 1082 Nicosia, P. O. Box 23378, 1682 Nicosia.
Tel: (+357) 22818456,
Fax: (+357) 22304565,
email: commissioner@dataprotection.gov.cy
the
Information Commissioner
1, Iasonos Street, 1082 Nicosia, P. O. Box 23378, 1682 Nicosia.
Tel: (+357) 22818456,
Fax: (+357) 22304565,
email: commissioner@dataprotection.gov.cy