Schirwindt Ltd (CY)

Schirwindt Ltd. 

Privacy Policy 

Schirwindt Ltd. is a company duly incorporated under the cap 113 of the Cyprus Companies Law. The company services international clients for services related to guidance on improving the level of adherence to and Compliance with the applicable legislation in the financial industry and is a producer of audio-visual artworks. The company itself is not a provider of any financial services and is not processing any investments. Furthermore, the company renders services related to management consulting, the production of business plans, feasibility and marketing studies and manuals as well as procedures.

Schirwindt Ltd.

Reg.No.: HE420736

PO Box 54011

3720 Limassol

Cyprus

www.schirwindt-ltd.com

schirwindtltd@mail.ru

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At Schirwindt Ltd. we respect the confidentiality of our clients’ personal information and thus we are committed to safeguard the security of any information Schirwindt Ltd. is provided with by our prospective and / or existing clients as well as by individual visitors of our corporate website www.schirwindt-ltd.com,  i.e. this website. This code of confidentiality applies for any further information, which a new client or respectively an existing client provides Schirwindt Ltd. within the course of electronic and physical correspondence with Schirwindt Ltd.

Collection of Personal Information 

In order to provide services to our clients efficiently and accurately, when each new client applies to register to use our services, we ask of them to submit certain personal information to Schirwindt Ltd. 

The term 'data subject' applies to clients of Schirwindt Ltd. Data subjects are all physical persons. Clients of Schirwindt Ltd., which are in the form of legal persons, are represented by their local Management and / or Universal Beneficial Owner(s) (UBO) and hence by individual persons. Therefore, the personal data collected from our clients can include information about the physical and legal persons full name, date of birth, home and work addresses and telephone numbers, email address, passport number/or ID number, marital status, government issued photo ID with signature, financial information such as estimated annual income, net worth, liquid assets. The disclosure of the information as mentioned within this paragraph to Schirwindt Ltd. is to be submitted willingly by the prospective and / or existing client and requires the explicit consent of that specific client or client representative(s).

Besides the above, we may also gather certain information about the clients' use of our services. This may include information from which they can be identified, such as the times they log on (for instance, IP address, type of computer or telecommunication device used for accessing our corporate website, geographical location and internet access service provider of an individual visitor), their volume of use of our corporate website, the types of data, systems and reports they access, duration of sessions and other similar data. This data as described in this paragraph is collected automatically by the IT infrastructure of Schirwindt Ltd.

Furthermore, Schirwindt Ltd. collects personal information, which is related to an individual visitor of our corporate website by the use of the contact form in the 'contact us' section of our corporate website.

At Schirwindt Ltd., incoming and outgoing telephone calls may be recorded for training and monitoring purposes.

In line with the requirements of the Data Protection Regulation 679/2016/EU, Schirwindt Ltd. fulfils the role of the Data Controller with regards to all data that the company collects from individual visitors of our corporate website www.schirwindt-ltd.com, as well as from all physical and electronic correspondence between our prospective and / or existing clients and Schirwindt Ltd. 

What information is collected?

Data to be collected:

Via the corporate website www.schirwindt-ltd.com, our IT infrastructure may collect the following data related to individual visitors of our corporate website:

- IP address of website visitor

- Geographic location of website visitor

- Internet Access Service provider of website visitor

- Type of computer or telecommunication device used by website visitor

- Frequency and duration of sessions per page visit by website visitor

- Data and documents of website accessed by website visitor

Via the contact form on our corporate website, the following data may be collected:

- Name

- Surname

- Contact email address

- Contact telephone number(s)

- Title (Mr.; Ms.; Mrs.; Dr.; Prof.)

- any additional information disclosed by the message submitted via the contact form

By entering into a business relationship and in the course of correspondence in physical or electronic form with Schirwindt Ltd., the following personal data may be collected:

From corporate clients

- Certificate of incorporation

- Certificate of shareholders

- Certificate of registered address

- Resolution of Directors

- Certificate of Incumbency 

- Certificate of good standing

- Audited financial statements

- Copies of Licenses granted to the corporate entity

- Information on corporate bank account numbers

- Set of contact data of corporate entity

- Set of contact data of employees and / or local management and / or Universal beneficial Owner

From individual clients and individuals representing a corporate client

- Copy of Passport

- Copy of ID card

- Proof of physical address of an individual

- Information and documents related to an individual's profession and /or employment

- Criminal record of an individual

- Documents on the Financial status of an individual (e.g. non-bankruptcy certificate)

- Professional certificates of an individual's professional background

- Documents regarding the educational background of an individual

- Documents related to the origin of wealth of an individual 

- Contact telephone number(s) related to an individual

- Electronic mail address related to an individual 

Uses Made Of Your Personal Information 

We at Schirwindt Ltd. collect information from our prospective and / or existing clients in order to enable us to administer, support, and obtain feedback on our services, to identify and prevent faults with our services and the corporate website of Schirwindt Ltd., to improve the services offered by us, to ensure we are maintaining adequate security measures, to prevent any security breaches of our website and IT infrastructure, as well as to keep prospective and / or existing clients informed about products and services that may be of interest to them. We may also use this information, for internal research and analysis purposes such as monitoring the website usage in order to help us develop the website and improve the services offered by Schirwindt Ltd. 

We at Schirwindt Ltd. also collect and process information as described in here above as to enable us to maintain regulatory and legal compliance when rendering our services to our prospective and / or existing clients. This concerns in particular the specific identification of a prospective and / or existing client when making use of the services offered by Schirwindt Ltd.

All use and processing of personal data, which relates to an individual visitor of our corporate website is subject to that person's (physical and legal person represented by its local management or UBO/s) explicit consent. 

Also, the use and processing of personal information and data, which relates to a specific prospective and / or existing client of Schirwindt Ltd. is strictly limited to the use as described within this privacy policy and subject to that prospective and / or existing client's explicit consent.

Further Uses Of Your Personal Information; Marketing 

In addition, we may process the personal data, which is related to our clients (physical individual person or legal person as represented by its local management or UBO) for marketing purposes and there are several ways in which we at Schirwindt Ltd. may use the personal information we have been provided with, including the following: 

 We may contact an individual client or the representative(s) of clients (when in the form of a legal person) in order to present services to which the client or its representative(s) do not subscribe and which may be of interest to them according to their client profile; 

 We may wish to provide an individual client or the representative(s) of clients (when in the form of a legal person) with information about special features of our Site that we think may be of interest to that client or client's representative(s); 

 We may provide an individual client or the representative(s) of clients (when in the form of a legal person) with information from our affiliates which we think may be of interest to that client or client's representative(s); 

 We may invite an individual client or the representative(s) of clients (when in the form of a legal person) to client functions or entertainment events; and 

 The above contacts may be via email, fax, post and/or telephone. 

If an individual client or the representative(s) of clients (when in the form of a legal person) does not or do not want us to use personal information, which is related to that client or its representative(s) specifically in this way, as an on-line subscriber, the individual client or the representative(s) of clients (when in the form of a legal person) may update the client account accordingly in order to amend the marketing preferences at any time. 

Schirwindt Ltd. has appointed a Data Protection Officer (DPO). This DPO remains independent within our corporate structure and has a direct connection to the top level management at Schirwindt Ltd. By submission of electronic correspondence to schirwindtltd@mail.ru an individual client or the representative(s) of clients (when in the form of a legal person) can get in touch with our DPO and submit a request with regards to the relevant specific personal information. 

Your Rights to your personal data

In line with the provisions and requirements of the Data Protection Regulation 679/2016/EU on the protection of personal data, our clients (physical individual clients as well as legal persons represented by its local management or UBO/s) remain the following rights to personal data, which relates to them specifically:

- The clients remain the right to review all personal information, which is related to a physical or legal entity and its representative(s) and which was / is collected during a visit of our corporate website and during the use and processing as described in this privacy policy at any time and to check the accuracy of personal data, which is related to the relevant physical or legal person and makes a physical person or legal person's representative(s) individually identifiable.

- All clients of Schirwindt Ltd. remain the right to have done corrections, rectifications and refreshments to their specific personal data.

- All clients of Schirwindt Ltd. remain the right to have the personal data, which relates to them as a physical person or to the legal person and /or its representative(s), deleted partly or completely.

- All clients of Schirwindt Ltd. remain the right to obtain information on the use and purpose to process the personal data, which relates to them specifically.

- All clients of Schirwindt Ltd. remain the right to limit the purpose for processing and use of personal data, which relates to the client or its representative(s) respectively. However, this may have an effect on the accessibility of our services rendered to that client. Our clients can refer to our DPO and our Compliance Department for further clarifications on this.

- All clients of Schirwindt Ltd. remain the right to opt-out from commercial and non-commercial newsletters and notifications from Schirwindt Ltd. by sending a notification to our DPO accordingly.

- All clients of Schirwindt Ltd. remain the right to have all personal data, which is related to them specifically and which is or had been collected during your visit and use of our corporate website and during the correspondence with Schirwindt Ltd., being transferred to another Data Controller nominated by the relevant client.

- All clients of Schirwindt Ltd. remain the right to withdraw the previously given explicit consent with regards to the collection, use and processing of personal data, which relates to the client or its representative(s), at any time by contacting our Data Protection Officer by electronic mail services to schirwindtltd@mail.ru. 

All clients of Schirwindt Ltd. can submit a request to make use of the above rights to personal data, which relates to that client or its representative(s) specifically, by contacting our Data Protection Officer (DPO) through electronic mail services to schirwindtltd@mail.ru. 

Disclosure of your information  

Schirwindt Ltd. will not disclose to any third parties any information or data, which enables the identification of our clients or the representative(s) and / or UBO(s) of clients that are in the form of a legal person, without that person's explicit consent. This applies for personal data, such as names, postal and e-mail addresses, telephone numbers, or other, which Schirwindt Ltd. had been provided with by an individual client or the representative(s) of clients (when in the form of a legal person).

The rendering of our services to our company's prospective and / or existing clients requires the disclosure of personal data related to our prospective and / or existing customers in order to fulfil requirements defined by the regulatory legal framework in the Republic of Cyprus. Hence, we may pass on information related to our prospective and / or existing clients to third parties. Schirwindt Ltd. ensures the confidentially treatment of all disclosed data to external parties. Schirwindt Ltd. will communicate the use of all personal data to an individual client or to representative(s) of clients (when in the form of a legal person) prior to its use or processing as described in this privacy policy. All clients of Schirwindt Ltd. remain the rights to their personal data as described within this privacy policy.

Personal data, which is collected during the visit of our corporate website and by the use of the contact form in the 'contact us' section of our corporate website may be disclosed to licensors of the software used on the Site. Please refer to our Data Protection Officer (DPO) in case you have questions on this or in case you want to make use of your rights related to your personal data as described in this privacy policy.

We may also disclose personal information related to an individual client or to representative(s) of clients (when in the form of a legal person) to third parties if we are under a duty to disclose or share the relevant personal data in order to comply with any legal obligation, or in order to enforce or apply our Site Terms and Conditions. Furthermore, that personal data is permitted to be disclosed to public bodies only in cases where the disclosure concerns matters of national and/or international security, the prevention or investigation of criminal activities, law enforcements, where a public interest is given, a juridical proceeding against the person, to which the personal data is related is pending or had been initiated or completed before and/or the personal security of the individual to which the personal data is related.

Your consent 

By submitting your information either through our corporate website www.schirwindt-ltd.com or by electronic or physical correspondence with Schirwindt Ltd., the individual client or the representative(s) of clients (when in the form of a legal person) consent to the use by Schirwindt Ltd. of that information, as set out in this policy. By accessing and using this website, an individual client or the representative(s) of clients (when in the form of a legal person) acknowledge that the client or its representative(s) have read, understood and agree with this privacy policy. 

You are aware that you can make use of the rights to your personal data as displayed in this privacy policy. We reserve the right to change our privacy policy from time to time and will update this page accordingly. Please review our policy as often as possible – your continued use of the Site will signify that you are made aware of any such changes. 

The Site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies or the content of external websites from legally and economically independent entities. Please check these policies before you submit any personal data to these websites. 

How we protect your information 

Schirwindt Ltd. takes responsible to store your information in its protected physical archives and protected electronic databases for reference in order to answer queries or resolve problems, provide improved and new services and to meet any legal data retention requirements and regulatory compliance requirements. This means we may retain an individual client's or client's representative'(s)' (when in the form of a legal person) information after that client or its representative(s) discontinue the use of the Site or our services or otherwise interacting with us over the applicable time period of five years, starting by the date of termination of relations with Schirwindt Ltd. 

All electronic information an individual client or the representative(s) of clients (when in the form of a legal person) provide us with is stored on secure and protected servers. The transmission of information via the internet is secured using Secure Socket Layer (SSL) technology with high security 128bit encryption. However, we have put in place various internal security procedures and a Business Continuity Plan (BCP) as set out in this policy. Once we have received your information, we strictly follow these procedures and security features in order to prevent unauthorized access. 

Failure to Provide Personal Information 

All clients of Schirwindt Ltd. have a choice to supply any or all of the personal information required. However, missing information may result in Schirwindt Ltd. being unable to open or maintain the relevant client account and /or to provide an individual client or the representative(s) of clients (when in the form of a legal person) with our services. 

If you feel the rights to your personal data had been infringed by Schirwindt Ltd., please get in touch with our DPO at schirwindtltd@mail.ru.