PRIVACY POLICY
Last updated: November 2025
1. IMPORTANT INFORMATION AND WHO WE ARE
This privacy policy gives you information about how Papadopoulos, Lycourgos & CO LLC collects and uses your personal data through your use of this website, including any data you may provide when you engage us to provide a service.
This website is not intended for children and we do not knowingly collect data relating to children.
Papadopoulos, Lycourgos & CO LLC is the controller and responsible for your personal data (collectively referred to as "Firm", "we", "us" or "our" in this privacy policy).
We are a lawyer’s limited liability company registered in the Republic of Cyprus, with registration no. HE 243954.
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact the us using the information set out in the contact details section (paragraph 10).
2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, maiden name, last name, any previous names, marital status, title, profession, date of birth and gender.
· Contact Data includes billing address, delivery address, business address, telephone number, mobile phone number, fax number and email address.
· Identification information includes ID number, passport number.
· Recruitment/selection Data includes academic qualifications, professional background and any other information contained in your CV, application form, record of interview or interview notes and any other assessment material.
· Financial Data includes data necessary for processing payments, including credit/debit card numbers, bank account, security code numbers and other related billing information.
· Further Financial and Business Data, includes data necessarily processed in a project or client contractual relationship with the Firm or voluntarily provided by you, such as instructions given, payments made, requests and projects.
· Special Categories of Personal Data (sensitive data): in connection with the provision of legal services to you, may on some occasions need to ask for certain sensitive information (e.g. information about your health, racial or ethnic origin etc.). The processing of sensitive data will only be carried out by us in full compliance with the GDPR and applicable national legislation, on the basis of your explicit prior consent.
· Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
· Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
· Profile Data includes your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you interact with and use our website.
· Details of your visits to our premises.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, there are circumstances in which the Firm cannot take action without certain of your personal data, for example because the collection of personal data is required to process with your instructions or orders or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for us to provide you with what you request without first obtaining the relevant personal data and we will notify you accordingly.
We use different methods to collect data from and about you including through:
· Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our services;
• engage us to provide services’
• subscribe to our service or publications;
• give us feedback or contact us.
· Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.
4. HOW WE USE YOUR PERSONAL DATA
Legal Basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
· Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
· Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for Which We Will Use Your Personal Data
The Firm uses your personal data for the purposes for which you have supplied it to us:
· for providing legal advice and/or other corporate and/or administrative services you may have requested;
· for responding to your requests for legal advice and/or other enquiries;
· for ensuring compliance with our legal obligations (e.g. for compliance with our obligations under applicable anti-money laundering laws);
· for the purposes of processing your application if you are a candidate for employment with the Firm;
· for complying with a court order and/or defending our legal rights, where applicable;
· for insurance purposes;
· for any purpose related and/or ancillary to any of the above or any other purpose for which your Personal Data were provided to us;
· where you have provided to us with your explicit prior consent, we may also use the information to provide you with newsletters, briefings and other publication about legal developments and matters which we believe may be of interest to you.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website.
You may block cookies by reviewing your internet browser settings, to exercise choices you have for certain cookies. If you disable or delete certain cookies in your internet browser settings, you might not be able to access or use important functions or features of our site.
5. DATA SHARING
We may share your personal data in the following circumstances:
· to our subsidiaries or affiliates to the extent this is necessary for the purposes of provision of services;
· to third parties to whom we outsource certain services, such as document processing and translation, confidential waste disposal, provision of IT systems, support or software, document and information storage;
· to third parties engaged in the course of services provided to clients such as counsel, arbitrators, mediators, clerks, witnesses, courts, opposing parties and their lawyers, as well as experts such as tax advisors or expert valuers;
· to other lawyers, other legal specialists, consultants or experts duly engaged with your instructions in your matter;
· to foreign law firms for the purpose of obtaining foreign legal advice upon your instructions;
· where we are required to do so by law or where it is necessary for the purpose of, or in connection with, legal proceedings or in order to exercise or defend legal rights;
· we may also share your personal data with any third party to whom we assign or novate any of our rights or obligations;
Otherwise, we will only disclose your personal data when you direct us or give us your express consent.
6. 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.
7. PERSONAL DATA OF OTHER INDIVIDUALS
If you provide us with personal data about another individual, you must ensure that you are entitled to disclose such personal data to us and that you have provided the relevant data subjects of all mandatory data privacy notifications and information under the GDPR and applicable legislation and regulation, to include a notification as to their legal rights as data subjects. For that purpose, you must also ensure that the individual concerned is aware of the contents of the present Privacy Policy, as those matters relate to that individual, to include our identity, how to contact us, the purposes of collection of the data, how we may use and/or share the data and his/her relevant rights.
8. DATA RETENTION
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
· Request access to your personal data (commonly known as a "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 in certain circumstances. 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 (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 of your personal data where we are relying on a legitimate interest as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
· You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes
· 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• 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
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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 could 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 could 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.
10. CONTACT DETAILS
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
· Email address: dataprivacy@paplyclaw.com
· Postal address: 2-4 Archbishop Makarios III Avenue, Capital Center, 7th floor, 1065, Nicosia, Cyprus
· Telephone number: 22676126
11. COMPLAINTS
You have the right to make a complaint to the Office of the Commissioner for Personal Data Protection, the Cyprus regulator for data protection issues (https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_el/home_el?opendocument). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We reserve the right to update and change this Privacy Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they posted on this website. This version was last updated on November 2025.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
13. THIRD-PARTY LINKS
This website, newsletters, email updates and other communications 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 encourage you to read the privacy policy of every website you visit.
