- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURE OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
Welcome to the I.ELIAS & CO LLC’s (ELIAS & CO) Privacy Notice.
ELIAS & CO respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how and why we collect and use your personal data and to also inform you about your privacy rights and how the law protects you.
2. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This Privacy Notice aims to give you information on how ELIAS & CO collects and processes your personal data including any data you may provide through this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice together with our Terms and Conditions and any other privacy related notices or fair processing notices we may provide on specific occasions from time to time. Such notices will ensure that you are fully aware of how and why we are using your data. This Privacy Notice supplements all privacy-related notices, which you had previously received and will receive in future, and it is not intended to override them.
ELIAS & CO is part of the EMCO Group which is made up of different legal entities which are either law firms, marine consultancy or insurance brokerage firms. The EMCO Group consists of:
- Elias Marine Consultants Limited – Cyprus
- Elias Marine Consultants SAL – Lebanon
- Elias Marine Consultants Ltd – Egypt
- I. Elias & Co LLC – Cyprus
- Elias Law Limited – United Kingdom
- Emira Insurance Agency SAL- Lebanon
- Emira Insurance Brokers Ltd – Cyprus
This Privacy Notice is issued on behalf of ELIAS & CO as a member of The EMCO Group, so when we mention ”the Company”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the EMCO Group responsible for processing your data. This website is owned by ELIAS & CO and together with The EMCO Group they are joint data controllers of any information gathered through this website.
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights please contact us using the details set out below.
Our full details are:
Full name of legal entity: I.ELIAS & CO LLC
Email address: privacy@eliaslawllc,com
Postal address: P.O. Box 5145, Limassol 3110, Cyprus.
You have the right to make a complaint at any time to the relevant Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach the Supervisory Authority so please contact us first.
Our representative in the United Kingdom is Elias Law Limited who is overseen by the Supervisory Authority for Personal Data Protection is the Information Commissioner’s Office (ICO) (www.ico.org.uk). The details of Elias Law Limited are as follows:
Elias Law Limited
4 Prince’s Court,
Dorset, BH22 9JG
Tel : 0044 (1202) 051222
Fax : 0044 (1202) 051223
Email : firstname.lastname@example.org
In Cyprus, the Supervisory Authority for Personal Data Protection is the Office of the Commissioner for Personal Data Protection (www.dataprotection.gov.cy.)
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
Any changes we make to our Privacy Notice in the future will be posted on this page and will be communicated to you when feasible.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we urge you to read the privacy notice of every website you visit.
3. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified either by itself or in conjunction with other data likely to be in our possession. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes company name, first name, maiden name, last name, marital status, title, date of birth, gender, copies of identification documents and address verification documents.
- Contact Data includes telephone and fax numbers, e-mail addresses, postal addresses and visiting addresses.
- Employment Data includes job position/title, company/organisation name, and history of employment, qualifications and area of expertise.
- Financial Data includes bank account details and transaction history and records.
- Transaction Data includes details about payments to and from you.
- Technical Data includes internet protocol (IP) address, your login data, cookies, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. It may also include receipts and clicks on e-mails we send from our automated e-mail system.
- Usage Data includes information about how you use our website.
- Service Data includes details about services that you have requested or were provided to you or your organisationsuch as complimentary services.
- Interest and Engagement with the Company includes data gathered at any time from interaction and engagement with the Company including personal and professional interests.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Access and CCTV Data includes a record and images of your entry and exit to and from our premises and your movements within our premises.
- Other Data includes data obtained during our provision of services to you or your provision of services or products to us in relation to a matter or incidental to our professional relationship with you (for instance information incidental to witness statements, correspondence, court or transaction documents) or during the provision of complimentary services such as arranging access for you or dietary requirements.
- Special Categories of Personal Data in certain circumstances, wemay also have information on your ethnic or racial origin, religious or philosophical beliefs and, where relevant, information about individuals’ criminal records or offences or even details as to sex life or preferences (for instance obtained through a disclosure process during a provision of legal services). Biometric data such as fingerprints may also be required for access control to our premises.
- Aggregated Data may also be collected, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not legally considered as personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Notice.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have, or are trying to enter into, with you. In this case, we may have to cancel our services to you, but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you through the following means:
- Direct interactions: You may give us your Identity, Contact, Employment, Service Data, Access and CCTV Data, Financial, Interest and Engagement, Marketing and Communications Data or other data by filling in forms, or by corresponding with us by post, phone email or otherwise. This includes personal data you provide when you :
- Register to receive our newsletters, alerts and invitations;
- Contact us about our services by email, telephone or through our website;
- Send us feedback by email, telephone or through our website;
- Fill out application forms , telephone or through our website;
- Send us CVs or resumes;
- Participate in interviews, meetings and other assessments;
- Request marketing to be sent to you; and
- Through any similar interactions in which you provided such data.
- Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources: We may receive personal data about you from various third parties as set out below:
- From the organisation in which you are employed;
- From other parties involved in a matter which we are dealing with;
- Information available in the public domain;
- Private investigators;
- Governmental authorities, agencies, departments and organisations;
- Recruitment Agencies;
- Personal references, from ex-employers for instance.;
- Background check providers;
- Credit reference agencies; or
- Technical Data: We may receive such data from the following sources:
(a) Analytics providers, such as Google and WordPress; MailChimp;
(b) Advertising networks, such as Shiparrest.com and Global Marine Investigators.
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter, or have entered, into with you. ‘Performance of Contract’ means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests, where there are no fundamental rights which override these interests. ‘Legitimate Interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Where we need to comply with a legal or regulatory obligation. ‘Complying with a legal or regulatory obligation’ means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Please refer to the below section to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you, via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Applicable to||Purpose/Activity||Type of data||Lawful basis for processing, including basis of legitimate interest||Who we share your Data with|
|Clients Visitors to our premises||New client / matter file and carrying out initial and subsequent checks as required by law and regulations.||(a) Identity (b) Contact (c) Employment (d) Financial (e) Service (f) Other (g) Access & CCTV Data||Performance of a contract with you. Compliance with our legal obligations. Necessary for our legitimate interest in dealing with matters on behalf of our clients, to protect our business, employees and premises and to prevent fraud. Special category data: In matters relating to legal proceedings or advice, and in establishing, exercising or defending legal rights.Suspicion of terrorist financing or money laundering.||Your organisation (where you work) Third parties and / or professional advisors, if necessary, when dealing with matters on your behalf. Regulatory and law enforcement bodies.|
|Clients Third Parties||Fulfilling our contractual and legal obligations, providing advice, services and / or information on payment and fees and to communicate these to you. To develop our business profile.||(a) Identity (b) Contact (c) Service Data (d) Financial Data (e) Interest and Engagement (e) Other (f) Marketing and Communications||Necessary for our legitimate interest: To provide advice and services and handle matters on behalf of our clients.to develop business relationships. to ensure network and information security and to prevent fraud. Special Category Data: In matters relating to legal proceedings or advice and in establishing, exercising or defending legal rights.Suspicion of terrorist financing.||Your organisation (where you work) Service providers on behalf of your organisation. Other parties involved in a matter. Third parties and / or professional advisors, if necessary, when dealing with matters on your behalf. Regulatory and law enforcement bodies.|
|Suppliers and Service Providers Clients Third parties Business contacts||To make and / or receive payments||(a) Contact (b) Financial||Performance of a Contract with you. Necessary for our legitimate interests for providing a service, receive payment and making payments on your behalf or to third parties.||Service providers, such as credit agencies, auditors, counsel, local lawyers, debt collectors, our bank.|
|Visitors to our website||To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation.|
|Visitors to our website Clients Suppliers Third Parties Business Contacts||To comply with legal and professional obligations in relation to our functions as a company.||(a) Identity (b) Contact (c) Employment (d) Financial (e) Marketing and Communications (f) Service Data (g) Other||Necessary to comply with legal obligations. Special category Data: In circumstances such as legal proceedings, legal advice and establishing, exercising and/or defending legal rights. The detecting and/ or prevention of unlawful acts.||Your organisation. Our advisors Governmental Bodies. Law enforcement Regulatory Bodies.|
|Visitors to our Website||To use data analytics to improve our website, products/services, marketing, client relationships and experiences.||(a) Technical. (b) Usage.||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).|
|Third parties Service Providers Clients||To allow third party service providers to carry out any of the above services or activities on our behalf.||(a) Identity (b) Contact (c) Employment (d) Marketing and Communications (e) Interests and Engagement (f) Financial (g) Service Data (h) Other Data||Necessary for our legitimate interest to appoint suppliers and service providers in support of our business.||All service providers engaged on behalf of your organisation or on our behalf.|
|Suppliers and Service Providers Third parties||To assess your suitability, or your organisations suitability, to provide the services we require.||Identity ContactEmployment Financial ServiceOther||Necessary for our legitimate interest to appoint suppliers and service providers in support of our business.||Our clients Your organisation|
|Suppliers and Service Providers||To appoint you or your organisation to provide a service on our behalf or on our clients’ behalf. To instruct you and communicate with you about what is required.||Identity ContactEmployment Financial ServiceMovementSpecial Data Other||Compliance with our legal obligations. Necessary for our legitimate interest to appoint supplier and service providers in support of our business. Special Category Data With explicit consent To detect and/or prevent unlawful acts or fraud.||Your organisation. Our clients. To third parties (where required) in relation to a matter. Governmental bodies. Regulatory bodies. Law enforcement bodies.|
|Clients Suppliers and Service Providers||To provide you or your organisation with references and recommendations.||Identity ContactEmploymentFinancial ServiceOther||Necessary for your legitimate interests or those of your organisation in support of our business.||Our business contacts. Your business contacts.|
|Visitors to our premises Suppliers Clients||To ensure security of our premises, for the prevention of unlawful and criminal acts.||Identity Access and CCTV dateOther||Necessary for our legitimate interest to keep our employees, third parties and business safe and to comply with our insurance contract obligations. Special category data: Your explicit consent.To protect personal vital interest.||Security service providers. Emergency services. Law enforcement agencies.|
|Visitors to our premises Suppliers and Service Providers Clients||To ensure compliance with our emergency and health and safety procedures.||Identity Access and CCTV DataSpecial Other||Necessary for our legitimate interest to keep our employees, third parties and business safe. To comply with our legal obligation Special category data : Your explicit consent.To protect personal a vital interest of yours.||Security service providers. Emergency services.|
|Applicants||Considering applications for employment at our Company.||Identity Contact EmploymentSpecial Other||Necessary for our legitimate interest in recruiting staff for our business. Maintaining and promoting equality in the workplace. Special category data: Criminal records where required by position held within the Company.||Recruitment agencies. Your organisation (for referrals). Our Human Resources team Senior managers. Other employees where required in performance of their role within the Company.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of relevance or interest to you.
You will receive marketing communications from us if you have requested information from us. Should you no longer wish to receive marketing material from us, then please send an e-mail to email@example.com or click on the option found at the bottom of all electronic marketing material.
We will get your express opt-in consent before we share your personal data with any company outside the EMCO Group for marketing purposes.
You can ask us to stop sending you marketing messages at any time by sending an e-mail to firstname.lastname@example.org or clicking the relevant option at the bottom of each email at.
Where you opt out of receiving these marketing messages, you will no longer receive marketing communication from us. Opting out of third party marketing messages, with whom you consented to opt in through us, should be requested from the relevant third party.
You should note that opting out of marketing communication will only apply to marketing purposes. It does not apply to personal data provided to us as a result of a service or business transactions.
COOKIES AND TRACKING TECHNOLOGIES
We use tracking technology to collect information on your activities on our webpage. This is done for instance when you open e-mails, view our webpage, through links to webpages when you RSVP to an event and when you unsubscribe. This information is used in order to assess that what is being sent to you is of interest. For events, RSVP’s are required to make appropriate event arrangements.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below, for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties which are the companies comprising the EMCO Group acting as joint controllers and processors who are based Cyprus, England, Lebanon and Egypt.
- External Third Parties:
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based Cyprus, England, Lebanon and Egypt who provide consultancy, banking, legal, insurance and accounting services.
- Revenue & Customs, regulators and other authorities acting as processors based in Cyprus, England, Lebanon and Egypt who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes, and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
We share your personal data within the EMCO Group. This will involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These are the “Standard Contractual Clauses for International Transfers”. For further details, see Standard contractual clauses for international transfers | European Commission (europa.eu).
Many of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
If the transfer of your data to a service provider is located in a country where adequate personal data protection is not in place, we will only do so if:
- The transfer is necessary for the establishment, exercise and/or defence of legal claims; or
- We have your explicit consent;
- The transfer is necessary for the performance of a contract in your interest and we are a party to the contract; or
- The transfer is necessary in order to perform a contract between us and you, or to carry out pre-contractual measures at your request.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
As the transmission of data through the internet is not completely secure and, although we do our best to protect it, the data transmitted to our website is at your own risk. After receiving your data, we will endeavour through procedures and security features to secure the data.
9. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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 reporting requirements.
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 unauthorised 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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request that your data is not processed for marketing purposes to the extent that it is related to direct marketing.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you 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 your personal data (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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing your personal data where we are relying on a legitimate interest (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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing 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 it 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 to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LINKS TO EXTERNAL FILES AND WEBSITES
Our website sometimes contains links to external files and websites. Such links are not a certification or declaration of affiliation in any way and we have no control of any such sites. We encourage you to read the privacy policies or statements of other websites you visit.