Pericleous Michail LLC is committed to protecting your privacy and personal data and we wish to be transparent as to how we do that through this Privacy Notice.

This Privacy Notice:

• Explains which types of personal data we collect from you when you visit and use our website (https://www.psml.law)(“website”), when you otherwise interact with us online but also when you interact with us offline;
• Addresses when, how and why your personal data is collected, processed and shared with third parties in the above instances;
• Informs you on your privacy rights, options and protection in line with the applicable data protection and privacy laws.

This Privacy Notice supplements but does not override any other privacy policy or notice we may provide when collecting or processing your personal data on specific occasions.

The data controller responsible for your personal data is PERICLEOUS MICHAIL LLC (Reg. No. HE 394781) (also referred to in this Privacy Notice as “we”, “us” or “our”), a Cyprus lawyers’ limited liability company.

• Full name of data controller: PERICLEOUS MICHAIL LLC
• Registered office address: 22 Griva Digeni Ave, 3106 Limassol, Cyprus
• Postal address: P.O. Box 54414, 3724 Limassol, Cyprus
• E-mail address: info@psml.law
• Telephone No. +357 25000070

If you have any questions or comments on this Privacy Notice, please send us an e-mail at info@psml.law.

Personal data is any information relating to an individual whose identity can be ascertained. We may collect and process data about you which is categorized as follows:

• Identity Data, such as your first name, surname, an online username or other identifier, date of birth, passport number, identity number, copies of your passport and identity documents including other documents containing your photographic identification, copies of utility bills and any additional identity data required by the Firm in order to meet its legal or regulatory requirements;
• Contact Data which includes your telephone number, e-mail address and postal address;
• Financial Data, such as data which is necessary for processing payments including your bank account details, payment card details and other related billing information and additional financial data processed necessarily or provided voluntarily in the course of a client engagement or contractual relationship with Pericleous Michail LLC;
• Business Data including all data relevant to litigation or other legal proceedings connected with you or a third party related to you, instructions, requests, business transactions or projects;
• Data relevant to meetings and visits to the Firm’s registered office address, including CCTV footage deleted automatically after 30 days.
• Marketing and communications Data such as your communication preferences in receiving e-mail newsletters and additional communication from us.
• Transaction Data which includes details about legal services you have requested from us and payments to and from you in relation to these purchases.
• Technical Data which includes your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Usage Data which includes information about your browsing activity on our website and any other domains or sub-domains we may from time to time create, including statistics on page views, links clicked and time on each page. 

We may aggregate Usage Data in order to measure the number of users accessing a specific area of our website and in order to improve the website’s look, feel and usability. Aggregated data is not considered ‘personal data’ in law, as it does not directly or indirectly reveal your identity, but we will treat any aggregated data which in combination with other data may directly or indirectly identify you as personal data which will only be used in accordance with this Privacy Notice.

We collect data from and/or about you using the following methods:

• Direct interaction – We may collect personal data apart from Technical and Usage Data directly from you when you meet with us in person or when you correspond with us by post, e-mail, through our website, by telephone or otherwise, including when you seek legal advice, representation or other legal, corporate or administrative services from us, make inquiries or otherwise interact with us via our website or client portal and fill-in any client intake forms we may provide;
• Automated interaction – We may automatically collect Technical and Usage data about your equipment, browsing actions and patterns while you visit or interact with our website, including through the use of cookies.
• Third parties or publicly available sources – We may receive personal data about you from various third parties, including technical data from data analytics providers and identity and/or contact data about you or your organization from publicly available sources, databases and records.

We sometimes place small data files called cookies on your device to make our website function properly. You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. Please note that parts of this website may become inaccessible or not function properly when you disable or refuse cookies. Please refer to our Cookie Policy for additional information.

Personal data about any third parties must be provided to us after ensuring you are entitled to disclose that personal data to us and that we may collect, use and disclose that personal data as described in this Privacy Notice without us taking any further steps. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices, the individual’s right to access personal data and make complaints about how that personal data is handled and the consequences if the personal data is not provided, such as our inability to provide services.

We plan to use or process your personal data for the Processing Purposes and on the Legal Grounds set out in the table below.

• We will not use or process your personal data for any purpose other than that for which we originally collected it, except where we reasonably consider the other purpose to be compatible to the original purpose. We will notify you in case we need to use your personal data for any unrelated purpose and explain the legal grounds on which we are allowed to do so.

We may not be able to perform a contract we have or are trying to enter into with you for the provision of legal services where we need to collect personal data from you by law or under the terms of the contract and you fail to provide such data. Where that occurs, we may be unable to enter into a contract with you and/or we may have to cancel an existing contract, but we will notify you if this is the case at the time.

We have a legitimate interest in operating, managing, developing, promoting and protecting our business. This includes, among other things, keeping our records up-to-date, preventing online fraud on or misuse of our website and improving our relationship with new or existing clients and third party service providers, by understanding how our customers engage with the products or services we provide, our third party service providers, our website and our marketing communications.

In practice, this means that, provided your own interests do not override our legitimate interests, we may process personal data personal data you provided to us when we develop and test for new products and services, improve existing products and services, plan for and organize future special events, prize-draws or promotions and create marketing material and communications.

We may process your personal data without your knowledge or consent, where this is required or permitted by law and where processing is compatible with other rules identified in this Privacy Notice.

We generally only rely on consent as legal grounds to process your personal data for the purposes of sending you direct marketing communications (please refer to the below note on marketing communications for more information). You can withdraw your consent for and opt-out from marketing-related communications from us and/or third parties instructed by us, or from participating in any prize-draw or promotion in which you initially registered at any time (please refer to “Withdrawal of consent” below).

We will only send you marketing-related communications if you have previously consented to us doing so by requesting information from us in writing regarding our services or if you have opted in to receive such communications by checking the relevant box and submitting your contact details through our website. 

Consent for marketing-related communications can be withdrawn by adjusting your marketing communication preferences through the links contained at the bottom of any marketing communication we or third parties instructed by us may send you or by contacting us using the contact details above.

We may share your personal data with the following third parties in order to meet certain Processing Purposes identified in this Privacy Notice:

• Third party domestic or foreign lawyers, legal consultants, legal or other experts and professional advisers engaged in relation to our engagements with you upon your instructions;
• Third party IT systems IT administration product and/or service providers;
• External professional advisers such as our accountants, auditors, bankers and insurers;
• External service providers for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and service providers delivering similar services, including financial institutions, credit reference agencies and regulatory bodies to whom such personal data is disclosed;
• Public authorities, Courts, Tribunals (including Arbitral Tribunals), regulators and law enforcement bodies (where we are required by law to do so or to the extent necessary for the establishment, exercise or defence of legal rights and equitable claims).
• Any other domestic or foreign external service providers or professional advisors instructed by our Firm to process personal data for any of the Processing Purposes on our behalf and in accordance with our instructions only. 

In such instances, we will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure data integrity and security.  

Pericleous Michail LLC has put in place appropriate security measures to prevent data loss, unlawful or improper use and unauthorized access or processing, including by limiting access to personal data to those employees, agents, contractors and other third parties who have a business need to know and only act under our instructions.

Personal data may be kept on our legal technology and data management software systems or in paper files.

We will only retain your personal data for as long as reasonably necessary to fulfil the Processing Purposes, satisfy our legal and accounting requirements, prevent fraud and resolve disputes, or until you exercise your right to erasure or revoke your consent (where applicable). Please refer to the “YOUR LEGAL RIGHTS” section of this Privacy Notice. 

We consider the following factors in order to determine the appropriate retention period for personal data:

• The amount, nature and sensitivity of the personal data;
• The potential risk of harm from its unauthorized use or disclosure;
• The Processing Purposes and whether these purposes can be achieved through other means; and
• The applicable legal or regulatory requirements.

We are required by law to maintain some information about our clients for tax purposes for a period of six (6) years after the expiration or termination of any lawyer-client engagement or contractual relationship with you. This information may include basic Identity data, Contact data, Financial data and Transaction data.

We will maintain information for a greater period if required or if we reasonably believe there is a prospect that we will be required to engage in litigation over our relationship with you.

You can request additional information on our data retention periods for different aspects of your personal data by sending us an e-mail at info@psml.law.

Under certain circumstances and subject to certain legal conditions, you have the right to:

• Request access to the personal data we hold about you;
• Withdraw your consent to us processing your personal data;
• Request the correction of any inaccurate personal data;
• Request the erasure of your personal data;
• Data portability;
• Object to the processing of your data or request that processing be restricted;
• Complain if you have a concern about how we handle your personal data.

If you wish to do any of the above please send an email to info@psml.law.

We will consider legitimate requests or complaints and try to provide a response within one (1) month.

In the event you are unsatisfied with our response, you have the right to lodge a complaint with the Cyprus Data Protection Commissioner’s Office, reachable at:

• Address: 1 Iasonos Street, 1082 Nicosia, Cyprus
• Tel: +357 22 818 456
• Fax: +357 22 304565
• e-mail: commissioner@dataprotection.gov.cy

It is important that we hold accurate and current personal data about you. In the event any of the personal data you have provided us changes or if you become aware that personal data we hold about you is inaccurate, please keep us informed by sending us an e-mail at info@psml.law.

Pericleous Michail LLC shall not be liable for any losses arising from inaccurate, inauthentic, incomplete or deficient personal data provided to us.

This Privacy Notice was last updated on 23/07/2019.

We reserve the right to occasionally amend and update this Privacy Notice and we may inform you by e-mail when we do. Any amendments or updates will become effective as soon as our amended or updated Privacy Notice is published on our website.