PRIVACY POLICY
General
A. Kouloundi & Co. LLC (“we,” “us,” or “our”) is a Lawyers Liability Company registered and existing under the laws of the Republic of Cyprus under registration number HE470561, having its registered office at Kodrou 16, Marylia Court, Flat 401, 3086 Limassol, Cyprus. We are committed to safeguarding personal data and upholding the highest standards of privacy practices.
This Privacy Policy aims to provide you with information on how we collect and process your personal data through your use of www.kouloundilaw.com (our “Website”), including any data about:
- persons we communicate with in the course of our business;
- persons whose personal data is provided to us in connection with the provision of our services;
- visitors to our Website, our LinkedIn page and/or any other social media page of ours;
- subscribers to or users of our online services, if any.
What data do we collect and process?
We collect and process data in the context of providing legal and affiliate services to our clients (existing or potential), which we receive from them directly or via their authorized representatives.
The data we may collect and process, subject to the particulars of each case, include the following:
- Personal Information: name, age, gender, date of birth, marital status, identification number, passport, nationality.
- Contact Information: business or residential address, phone number, email address.
- KYC and AML Information: information on financial wealth, assets held, source of funds and source of wealth, tax status, prominent public function status (PEPs) and more.
- Financial Information: payment-related information, bank account details, credit card numbers or financial records and more.
- Any other information required in the course of our business and/or to meet legal and regulatory requirements.
What is the purpose of and legal basis for processing your data?
A. Kouloundi & Co. LLC guarantees that the data it collects and processes is directly relevant to one or more specific processing activities. It ensures that only the necessary amount of data is collected and processed—neither more nor less than what is reasonably required to fulfill the purpose of each activity.
Subject to any agreement in writing between the personal data provider and us, the purposes for which we use personal data and the indicative legal basis for why that processing is necessary or permitted are:
| Purpose | Legal Basis |
| Communicating with persons in the course of our business. | To support our legitimate interests in managing our business and/or in providing services to our clients, unless otherwise mandated by applicable law. |
| To establish a client relationship and for providing our services to clients | To support our legitimate interests in managing our business and/or in providing services to our clients, unless otherwise mandated by applicable law. Where an individual has provided personal data, the processing of such data is specifically subject to the individual’s consent, which he/she may withdraw at any time by sending an email to dpo@kouloundilaw.com. |
| Maintaining and operating our website | To support our legitimate interests in managing our business and/or in providing services to our clients, unless otherwise mandated by applicable law. |
| To meet all legal, regulatory and ethical obligations applicable to us (such as under anti-money laundering legislation or for the purpose of responding to a binding request from a public authority or court and so on). | To support our legitimate interests in complying with our legal obligations. |
| To promote, improve and further the provision of our services and follow up on comments, enquiries and complaints. | It is in our legitimate interests as a legal service provider to collect and process certain personal data to enable it to follow up on comments, enquiries and complaints in order to enhance client/user experience. Where an individual has provided personal data, the processing of such data is specifically subject to the individual’s consent, which he/she may withdraw at any time by sending an email to dpo@kouloundilaw.com. |
| For marketing purposes including sending updates on important legal developments and news. | To support our legitimate interests in managing our business and/or in providing services to our clients, unless otherwise mandated by applicable law. Where an individual has provided personal data for marketing purposes, the processing of such data is specifically subject to the individual’s consent, which he or she may withdraw at any time by sending an email to dpo@kouloundilaw.com with subject “Consent Withdrawal”. |
Disclosure of your data
We may disclose personal data to:
- Third parties to the extent that such disclosure has been expressly and in writing authorized by you;
- Third parties to the extent that the data disclosed has already entered the public domain in circumstances not engaging our liability;
- Third parties to the extent that such disclosure is required pursuant to applicable law;
- Third parties in the context of any judicial or other proceedings for the settlement of any dispute arising out of or in connection with any agreement with you (including a dispute relating to the existence, validity or termination of such agreement or any non-contractual obligation arising out of or in connection with such agreement), so long as the disclosure is made in good faith;
- Third parties in the course of defending ourselves in the context of any administrative and/or disciplinary and/or civil and/or criminal proceedings anywhere in the world, to the extent that, acting in good faith and reasonably, we resolve that such disclosure is necessary for properly defending ourselves;
- Third party providers of accounting and/or actuarial and/or auditing and/or banking and/or business consulting and/or business management/administration and/or human resources and/or insurance and/or technology and/or legal and/or regulatory compliance and/or security (such as data security etc.) and/or tax services to A. Kouloundi & Co. LLC, to the extent necessary for the purposes of the provision of such services to A. Kouloundi & Co. LLC and provided that the relevant provider is subject to a duty of confidentiality;
- Third parties where it is necessary to protect the vital interests of the data subject or another natural person.
Transfer of your data outside of the European Union
To the extent that it is necessary to transfer personal data outside of the European Union, we will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data pursuant to applicable law.
Third-Party Websites
Our website may, from time to time, contain links to third-party websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies, and we do not accept any responsibility or liability for those policies. We urge you to check those policies before you submit any personal data to them.
Data Retention
We will retain your personal data only for as long as is necessary in order to fulfil the legitimate purposes we collected it for, unless a longer retention period is required or permitted under applicable law. After the fulfillment of the purposes for which the personal data was collected, such data will be destroyed, unless destruction is prohibited for legal, regulatory or technical reasons.
Data Security
We have implemented robust security measures to protect your personal data from accidental loss, unauthorized access, alteration, or disclosure. Access to your personal data is restricted to employees, agents, contractors, and third parties who require it for specific purposes. These parties are permitted to process your personal data only in accordance with our instructions and are bound by strict confidentiality obligations.
We have established procedures to address any suspected personal data breaches. In the event of a breach where legally obligated, we will notify you and the relevant regulatory authorities.
However, it is important to note that no physical or electronic security system is completely infallible. While we take every precaution, we cannot guarantee the absolute security of our databases or ensure that information you transmit to us—whether over the Internet or through other means—will not be intercepted. Such transmissions are conducted at your own risk. If we have provided you with a password to access specific sections of our website, you are responsible for maintaining its confidentiality. We strongly advise against sharing your password with anyone.
Cookies
Our website utilizes cookies to improve your browsing experience, serve personalized ads or content and analyze website traffic. When you first visit our Website, you will be presented with a cookie banner that asks for your consent to use non-essential cookies. You can accept, reject, or customize your preferences. By consenting, you agree to the use of
cookies as described here. Your consent can be withdrawn at any time by adjusting your browser settings or clearing your cookies. For further details about how we use cookies and the types of data they collect, please feel free to contact us at info@kouloundilaw.com.
Legal Rights
To the extent that we are a controller of your personal data you may request access to, rectification, or erasure of your personal data, or restriction of processing or object to processing of your personal data, as well as the right to data portability, which may be subject to restrictions.
The following is a summary of your rights (which, as stated above, are or may be subject to restrictions) in terms of the personal data we hold about you:
- Right of access enables you to receive a copy of your personal data.
- Right to rectification enables you to correct any inaccurate or incomplete personal data we hold about you.
- Right to erasure (“right to be forgotten”) enables you to ask us to delete your personal data in certain circumstances. Please note however, that this may not be exercised earlier than the end of any relevant period set by anti-money laundering and/or other applicable law, otherwise such law will be violated.
- Right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances, such as in case your personal information is inaccurate or unlawfully processed.
- Right to object enables you to object to us processing your personal data in certain circumstances.
- Right to transfer enables you to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to obtain a copy of it and reuse your personal data for your own purposes.
- Right to withdraw consent enables you to withdraw at any given time the consent that you gave us for processing your personal data, which does not however affect any lawful processing that took place prior to such withdrawal.
As required by the Cyprus Bar Association, we emphasize that the rights referred to above are not absolute, especially in relation to the fulfilment of our duties as a law firm and/or the Cyprus Bar Association in accordance with anti-money laundering and/or other legislation
and the need to avoid obstructing or jeopardizing money laundering and/or terrorist financing inquiries, analyses or investigations.
Contact Us
All enquiries in respect of this Privacy Policy or any requests to exercise any of your rights set out above or any complaints should be directed to our Data Protection Officer at dpo@kouloundilaw.com.
Right to Lodge a Complaint
If you still consider that the processing of your personal data infringes the Regulation (EU) 2016/679 (GDPR), you have the right to fill in a complaint form, and send it to the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus:
Kypranoros 15, Nicosia 1061, Cyprus
P.O.Box 23378, 1682 Nicosia, Cyprus
Tel: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
Changes to this Privacy Policy
This Privacy Policy has been prepared in accordance with the provisions of the EU General Data Protection Regulation (EU) 2016/679 (GDPR).
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements relating to privacy and personal data, including GDPR. You will be bound by any changes to this Privacy Policy by the time that such changes are uploaded on our website, to the maximum extent permitted by applicable laws and regulations.
Last Updated: February 2025