Legal Notices – Smirnov Advisors

Disclaimer

Last updated: 22 February 2023

Smirnov Advisors is an advisory practice operated by Reacose Advisory Limited, a limited liability company registered in the Republic of Cyprus with registration no. HE 440469 (“we”, “us” or “Smirnov Advisors”). Our registered office is at Arch. Makariou III, 276, LARA COURT, Limassol 3105, Cyprus.

The materials contained in this web site are for general information purposes only. They do not constitute an offer, legal or other professional advice. Neither Smirnov Advisors nor any of its directors or employees shall be responsible for any direct or indirect (including without limitation, consequential) loss which may arise from or in connection with the use of this website or reliance on information contained in this website. We do not warrant that the website or its contents are free of viruses or other harmful components. This website may contain links to external internet sites, and other external internet sites may link to this web site. We are not responsible for the content of any external internet sites.

Privacy Policy

Last updated: 22 February 2023

We at Smirnov Advisors recognize the importance of privacy and confidentiality of your personal information and are committed to collect and process your Personal Data in full compliance with the General Regulation on the Protection of Personal Data of the European Union (Regulation 2016/679) (“GDPR”) and the applicable Cyprus laws and regulations. Given this, we have developed this Privacy Policy to govern the collection, use, disclosure, transfer and storage of your Personal Data. Please read the Privacy Policy carefully to understand how we treat and process your Personal Data.

In this Privacy Policy personal data (“Personal Data”) means any identifiable information about an individual that can be used to contact or identify you.

References in this Privacy Policy to “we”, “us” and “our” are references to Smirnov Advisors. References to “you” and “your” are to the individual/s who is/are providing personal data to us.

The entity responsible for processing of your Personal Data is:

Reacose Advisory Limited
Arch. Makariou III, 276, LARA COURT, Limassol 3105, Cyprus
[email protected]

Please contact us at the above details if you have any questions or want more details on how we process your Personal Data.

Types of Personal Data we collect

We use your Personal Data for the purposes for which you have provided it to us, to include:

for providing services you have requested;
to notify you about changes to our services;
for responding to your requests for legal advice and/or other enquiries;
for ensuring compliance with our legal obligations (e.g. for compliance with our obligations under applicable anti-money laundering laws);
for complying with a court order and/or defending our legal rights, where applicable;
for insurance purposes;
for any purpose related and/or ancillary to any of the above or any other purpose for which your Personal Data were provided to us;
to carry out our obligations arising from any contracts entered into between you and us and to provide you with information, products and services that you request from us;
to detect, prevent and address technical issues.

We will only collect and process your Personal Data for the purposes for which you provided it to us, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. In any case, you can choose not to provide us with certain Personal Data, however, that may result in us being unable to provide you with certain services.

Data Sharing

We may transfer your Personal Data in the following situations:

to our employees and affiliates and their employees to the extent this is necessary for the provision of services to you;
to third-party providers to whom we outsource certain services, such as IT support, software, document and information storage, document translation;
to third parties engaged in the course of provision of services to you such as outsource legal counsel, other lawyers, consultants or experts duly engaged with your instruction;
where we are required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency) where it is necessary for the purpose of, or in connection with, legal proceedings or in order to exercise or defend legal rights;
we may also share your personal data with any third party to whom we assign or novate any of our rights or obligations;
to external legal or other consultants and associates;
to auditors and financial organisations.

Otherwise, we will only disclose your personal data when you direct us or give us your express consent.

Retention of your Personal Data

We will keep your Personal Data for as long as we have a business relationship with you. After the expiry of such business relationship, we may keep your data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

What data protection rights you have

Subject to the regulation, you have certain rights regarding the Personal Data we collect, use or disclose and that is related to you. If you would like to exercise, or discuss, any of these rights, please do contact us using the details set out above. At our discretion we may require you to prove your identity before providing the requested information.

In certain circumstance, you have the right

To access and receive a copy of the Personal Data we hold about you;
To rectify any incomplete or inaccurate Personal Data that we process about you;
To request the deletion of Personal Data held about you;
To request that we restrict our processing of your Personal Data in certain circumstances;
To data portability for the information you provide to us. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it;
To object to processing of your Personal Data in certain circumstances;
To withdraw consent to our processing of your Personal Data;
Right to lodge a complaint with the supervisory authority in Cyprus if you are concerned about any aspect of our privacy practices, including the way we’ve handled your Personal Data.

Cookies

We use cookies and similar tracking technologies to track the activity on our service and hold certain information.

A Cookie is a piece of data stored on your computer device containing some information. Cookies are sent to your browser from a website and stored on your device.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, certain parts of our website will not be available to you and some other parts might not behave as expected. In addition, you may not be able to use some portions of our service.

Changes to the Privacy Policy

We reserve the right to update and change this Privacy Policy from time to time in our sole discretion. Any changes take effect immediately upon being posted on our website and the modified version supersedes any prior versions of the Privacy Policy upon being posted on our website.

Upon continuing to use our website you acknowledge, agree and consent to the updated Privacy Policy.