Privacy Policy

ZK KROKOU & ASSOCIATES LLC (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and Laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Privacy Notice

1. Who We Are

ZK KROKOU & ASSOCIATES LLC was established in 2020 as a boutique law firm under the supervision of the Cyprus Bar Association.

2. Information That We Collect

This policy is addressed to individuals outside ZK KROKOU & ASSOCIATES LLC with whom we interact, including individual clients, representatives, directors, direct or indirect shareholders, beneficial owners and other stakeholders of client organizations, visitors to our website, other users of our services and suppliers.

ZK KROKOU & ASSOCIATES LLC processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and will not process your information in any way, other than as specified in this notice.

According to the General Data Protection Regulation (2016/679), personal data is defined as any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

3. The type of data that we may collect and process are:

• Contact details (including names, postal addresses, email addresses and telephone numbers);
• Information required to meet legal and regulatory requirements, in particular in respect of anti-money laundering legislation, including identification documents, name, address, passport/ID copies, information on source of funds and source of wealth;
• Information provided in the course of the provision of legal and governance services (for example, information on professional relationships and background, financial wealth and assets held, transactions entered into, tax status, disputes and court proceedings engaged in);
• Financial information, such as payment related information;
• Professional interests and events attended;
• Meetings attended and visits to our offices;
• Any other information you may provide to us.

4. We collect information in the below ways:

• Directly from you, as part of our business intake procedures when you provide it to us;
• In the course of our relationship with you, e.g. when you email us or provide such data to us;
• you make public: we make collect about you personal data that you choose to make public;
• When you or your organization or business associates seek legal advice or legal, administrative, corporate, trust and other services from us;
• When you or your organization offer or provide services to us as our vendor;
• When you send us information through our website;
• Through screening providers who assist us with our legal obligations to conduct under anti-money laundering, sanctions screening and regulatory checks;
• From law enforcement authorities
• From public records / sources.

5. How We Use Your Personal Data

We consider your privacy very seriously and, subject to what is provided in this Privacy Policy, will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:

• Service provision: providing legal advice and legal, administrative, corporate, trust and other services;
• Business relationship: managing and administering our relationship with you, your company or organisation including keeping records about business contacts, services, billing and collection, and payments; operating and managing our website and services provided to you, communicating and interacting with you and notifying you of any changes to our website or services;
• Communication: sending emails, newsletters and other messages to keep you informed of legal developments, market insights and for marketing of our services;
• Client compliance check: Know your client checks and confirming and verifying your identity. Client due diligence checks (under anti-money laundering, sanctions screening and other crime prevention and detection laws and regulatory requirements) which may involve automated screening checks to ensure that clients and contacts are genuine and to prevent fraud or crime and we may not be able take instructions if you do not provide the information we need to do these checks;
• Site security: to provide security to our offices and other premises;
• Online security: protecting our information assets and technology platforms from unauthorised access or usage and to monitor for malware and other security threats;
• Compliance: compliance with court orders, applicable law and other legal and regulatory requirements and obligations and also to exercise or defend legal claims or proceedings;
• Legitimate interest: to pursue the legitimate business interests listed in the “Legitimate Interests” section of this policy below.

6. Legitimate interests

We have legitimate business interests in:

• providing legal advice and legal services, administrative, corporate, trust or other services to you;
• managing our business and relationship with you or your company or organisation;
• understanding and responding to inquiries and client feedback;
• improving our services and offerings;
• receiving information from companies in our group of companies for shared clients;
• enforcing our terms of engagement and website and other terms and conditions;
• ensuring our IT and communication systems and premises are secure;
• ensuring debts are paid.

7. Disclosures of your personal data to third parties

We may disclose your information with others as follows:

• Firms in our group of companies: we may share your personal data between our Group of companies entities, including their management, lawyers, staff and contractors in order to provide legal advice and legal, administrative, corporate, trust and other services and for administrative, billing and other business purposes;
• Clients: if we have collected your personal data in the course of providing legal, administrative, corporate, trust or other services to any of our clients, we may disclose it to that client and where permitted by law, to others for the purpose of providing those services;
• Trusted third parties: we may share your personal information with certain trusted third parties which provide services to our group of companies, such as our professional advisers and auditors, suppliers and processors to whom we outsource certain support services, IT service providers, software providers, communication suppliers. We shall take measures to protect the confidentiality and security of the personal data in such circumstances;
• Third parties which provide professional services to your company or organization provided we are requested by you or your company or organization to do so;
• Law enforcement bodies and regulators: courts, tribunals, or other competent authorities in accordance with legal requirements or to exercise or defend a legal claim. We may be required to disclose your information to comply with legal or regulatory requirements;
• Any party as needed in connection with legal proceedings;
• Your company or organisation: in relation to us providing legal, administrative, corporate, trust and other services;
• Screening service providers, financial institutions and regulatory bodies: so that we can comply with legal obligations in relation to the prevention or protection of crime, fraud, anti-money laundering, sanctions screening and other required checks;
• Registrars of public records: when we have a legal obligation to proceed with any registration in public records.

Otherwise, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

8. Personal data about others

In some cases, you may provide personal data to us about other people (such as your customers, directors, officers, employees, shareholders or beneficial owners). You must ensure that you are entitled to disclose that personal data to us and that, without taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Policy. In particular, you must ensure that the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual.

9. Data Transfers outside the European Economic Area

Other than disclosures in accordance with section 7 above, we shall not transfer your personal data outside the European Economic Area (EEA).

10. Security

We have implemented appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, altered, disclosed, used or accessed in an unauthorized way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Where will your information be held?

Personal data may be kept on our personal IT systems, those of our contractors or in paper files.

12. How long do we keep your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or regulatory reporting requirements.  We will, in particular, retain your personal data where required to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

13. Your Legal Rights

You have rights under data protections laws in relation to your personal data. If you would like to exercise, or discuss, any of these rights, please contact office@zk-law.eu. We may require proof of your identity before we can give effect to these rights.

You have the right to:

• Request Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it;
• Request Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected, though we may need to verify the accuracy of the new data you provide to us;
• Request Erasure: you are entitled to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. There are also certain exceptions where we may not always be able to comply with your request for erasure, for specific legal reasons which will be notified to you, if applicable, at the time of your request. One example is where the personal data is required for compliance with law or in connection with claims;
• Object to processing: where we are processing your personal data based on legitimate interests (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. However, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes;
• Request Restriction of Processing: you are entitled to ask us to suspend the processing of certain of your personal data, in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds or a legal obligation to use it;
• Request Transfer: you may ask us to help you request the transfer of certain of your personal data to another party;
• Withdraw Consent at any time: where we are processing personal data with consent, you can withdraw your consent at any time;
• Right to lodge a complaint with the supervisory authority in Cyprus, the Office of the Commissioner of Personal Data (www. dataprotection.gov.cy).

14. Direct Marketing

We may use the information you give us for direct marketing from. You can opt-out of receiving direct marketing from us at any time by sending an email to office@zk-law.eu.

15. Links to third party websites

Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the wesbsites of others. The personal data that you provide through these websites is not subject to this privacy policy and the treatment of your personal data by such websites is not our responsibility. If you follow a link to any other websites, please note that these websites have their own privacy policy which will set out how your information is collected and processed when visiting those sites.

16. Changes to this Privacy Notice

This Privacy Policy will remain in effect except with respect to any changes in its provisions in the future. Any updates will appear on our website at www.zk-law.eu