West Guard Consulting Limited (Cyprus) values your confidentiality and protection of your personal data, and we comply with the principles of data processing set forth in this confidentiality policy. We consider the integrity and confidentiality of your personal data important and guarantee the legality of processing of personal data. The confidentiality policy explains how we collect and use personal data, including that from our site www.westguardconsulting.com

West Guard Consulting Limited (Cyprus) is the operator of your personal data; its registration number of a legal entity: 673997, the address: Konstantinou Skokou 1, Capital Chambers, 1061, Nicosia, Cyprus, the contact phone number: +357 96 006 397, the e-mail address: info@westguardconsulting.com (hereinafter referred to as "West Guard Consulting" or "We" in the relevant form)

1. Clarification of the terms

Personal data means any information pertaining to an identified or identifiable physical person ("data subject"); an identifiable physical person is a person, which can be identified directly or indirectly, in particular, through reference to an identifier, e.g., given name and surname of the indicated person, personal number, data on the location, network identifier, or one or several factors characteristic of the physical, physiological, genetic, psychic, economic, cultural or social identity of the indicated physical person;

Processing of personal data means any operation or totality of operations with personal data or totalities of personal data, using automated means or refraining from using them, e.g., collection, registration, organization, structuring, storage, adaptation or transformation, review, perusal, use, dissemination by post or otherwise, making the data available, reconciliation or combination, limitation, deletion or destruction;

The Operator (Manager) is a physical person or legal entity, public institution, agency or another structure, which either independently or jointly with others determines the targets and means of the processing of the personal data; if the targets and means of such processing are stipulated in the legislation of the Union or a member state, then the manager or specific criteria of his/its appointment may be stipulated in the legislation of the Union or a member state;

The Processor is a physical person or legal entity, public institution, agency or structure, which processes personal data on behalf of the manager;

Third party is a physical person or legal entity, public institution, agency or structure, which is not a data subject, manager, processor and persons, which, being directly subordinate to either the manager or the processor, are empowered to process the personal data;

The data subject is a person, the personal data of which is processed (the client – a physical person, site user or contact person of a legal entity).

2. The principles

West Guard Consulting and the processors working for us process the personal data complying with the following principles:

• Legality, integrity and transparency – the personal data is processed lawfully, in good faith and in a transparent manner for the data subject;
• The target limitation – the personal data is collected for specific, clear and legitimate purposes, and their further processing does not take place in a manner incompatible with these purposes;
• Data minimization – the personal data is adequate, relevant and incorporates only the information, which is necessary for the purposes of the data processing;
• Accuracy – the personal data is accurate and is updated if necessary. All reasonable measures must be taken to ensure the deletion or correction of inaccurate personal data without delay, taking into account the purposes of the data processing;
• Limitation of storage – the personal data is stored in a manner, which allows the identification of the data subjects not longer than it is necessary for the purposes, for which the relevant personal data is processed;
• Integrity and confidentiality – the personal data is processed in a manner ensuring adequate security of the personal data, including protection from unauthorized or unlawful processing and from accidental loss, destruction or damage, using the relevant technical or organizational measures.

3. Processing security

West Guard Consulting applies the necessary organizational, physical and technological measures to protect the personal data according to the risk. These measures incorporate regulations and procedures for the employees, data management and IT infrastructure management, management of the internal and external networks, as well as protection of all equipment and premises of West Guard Consulting.

West Guard Consulting provides the relevant training for all personnel processing the personal data.

West Guard Consulting may use processors to process the personal data. We ensure that all our processors process the personal data in accordance with our instructions and the existing legal acts, and take all the necessary organizational and technological security measures.

4. Legality of processing

West Guard Consulting processes the personal data in order to ensure the fulfilment of a contract, compliance with the legal obligations based on the lawful interests or agreement by the data subject.

We process the personal data in order to ensure the fulfilment of a contract in cases when the purpose of the contract cannot be achieved without processing the personal data.

The duties of the processing of the legal obligations incorporate the processing of all personal in accordance with the existing laws and regulations, for example, the Labour Law, the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing, the law "On Accounting".

We process the personal data in lawful interests, in order to improve the quality of our services and to develop our business. To ensure that our legitimate interests do not restrict the fundamental freedoms and rights of data subjects, we conduct a three-part check to ensure that the processing is purposeful, necessary and proportionate to the stated purpose.

Processing the personal data based on agreement by the data subject, we process specific data only, to which the data subject has given his/her consent. The consent is given freely, specifically and being informed. The data subject can revoke consent at any time and as easily as it was given.

5. The data operator/processor and generalization of data

West Guard Consulting may be either the operator or the processor in different operations aimed at the data processing. To ensure the right of the data subjects to confidentiality, West Guard Consulting complies with the confidentiality principles and strictly limits the dissemination of the personal data.

Only empowered persons of West Guard Consulting have the right to amend and process the personal data.

West Guard Consulting processes the personal data received either from the data subject directly (i.e. from the person providing the personal data) or indirectly (regarding the corporative clients). The personal data obtained indirectly is processed only in the case if we need to process the personal data to provide a service.

6. Categories of personal data

Personal data: given name, surname, personal number, date of birth.

The contact information: e-mail address, telephone number, residence address.

The personal data acquired indirectly, which we process for providing consultative services, may incorporate, inter alia, the following data: given name, surname, personal number, number of children, marital status, e-mail address, telephone number, residence address, size of income, bank account number, shareholders, enterprise owners and property rights.

The network data: data on the sessions of the site users, cookie files, journal data and IP-addresses.

7. The purpose of processing the personal data

The purpose of the data processing mentioned in Section 6 of this Policy is as follows:

• to provide tax, legal and other consultative services;
• to disseminate news and carry out studies of the clients' satisfaction;
• to process invoices for the provision of services;
• to comply with legal obligations and actions resulting from them.

8. Storage of the personal data

West Guard Consulting stores the personal data only as long as it is necessary for the achievement of the purpose for which the data is processed, unless applicable legal obligations exist stipulating otherwise. We store the data:

• in accordance with the law "On Accounting", accounting documents are stored for the duration of 10 years;
• the data generalized based on the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing is stored for 5 years after the completion of the business relations.

West Guard Consulting destroys and/or deletes in a safe manner all personal data, which either has served its purpose or due to the expiry of the storage term.

9. Third parties and data processors

West Guard Consulting transfers the personal data to third parties and data processors only if necessary based on the following purposes:

• management of the client relations, including service providers, e.g., providing the delivery services, call centers and others providing services to West Guard Consulting;
• to improve the quality of our services.

Irrespective of access limitations, West Guard Consulting will provide documents to an organization or person having a legal right to demand the data (e.g., the police, the court, a supervisory authority, etc.).
Please pay attention to the fact that your personal data may be transferred outside the European Economic Area (EEA). Your personal data is transferred outside the EEA if the following conditions are complied with:

• the data is transferred to our trusted partners only, which participate in the provision of services to you;
• data processing contracts have been signed with such partners, with the purpose of ensuring the security of your personal data, as demanded by the legislation;
• the European Commission has made decision on the acceptability of the country, in which our partner has been incorporated and the proper security level has been ensured;
• The partners ensure the security level of personal data in accordance with the EU-US Privacy Shield.

10. The rights of the data subject

The data subject has the right to receive information about the processing of his/her personal data. The data subject may receive a copy of his/her personal data at the disposal of West Guard Consulting, by sending a request to the e-mail address info@westguardconsulting.com.

West Guard Consulting has a legal obligation to ascertain that the person requesting information about him/her is in reality the person entitled to the receipt of the data. For that reason, the applicants may be requested to confirm their identity or their right to request the data.

The data subject has the right to the deletion of the personal data, if the processing of the personal data has been executed based on agreement by the data subject.

The data subject has the right to limit the processing of the personal data.

If it is possible, the data subject the right to the data transposition. The right to the data transposition means that you have the right to receive the personal data associated with you, which you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer that data to another operator.

The data subject has the right to submit a complaint to the Data Protection Inspectorate concerning the processing of personal data.

11. Cookie files

The site www.westguardconsulting.com, administered by West Guard Consulting Limited, uses cookie files to make the users' experience on the site more convenient.

Cookie files are small text files that the browser automatically saves to the device used by the user.

We use cookie files to collect anonymous and aggregated statistics on the number of visitors to our site and information on how this site is used in order to make our site more user-friendly.

It is possible to reject or block cookie files on your device, which may cause the website to malfunction, and not all services may be available. To reject or block cookie files, you need to change your browser settings.

12. Changes in the confidentiality policy

Data confidentiality is important for West Guard Consulting, and we update this privacy policy regularly. The version published on theWest Guard Consulting website is always the latest version of the policy.

If you have any questions, doubts or suggestions regarding the processing of personal data, please contact the data operator using the following contact information: the address: Konstantinou Skokou 1, Capital Chambers, 1061, Nicosia, Cyprus, the contact phone number: +357 96 006 397, the e-mail address: info@westguardconsulting.com.

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