Privacy Policy

TIRONA LIMITED ("TIRONA," "we," "us," or "our" in this Privacy Policy) holds a profound regard for your privacy, recognizing that safeguarding the security and confidentiality of your personal data is of paramount significance. This Privacy Policy expounds on how we handle and protect your personal data, delineates your privacy entitlements, and elucidates the legal safeguards in place when:

  • You navigate our website.
  • You are a current or potential client of ours.
  • You are listed as a contact in our records.
  • You are associated with our clients or potential clients, or you are linked to matters for which we receive instructions from our clients.

It is imperative that you thoroughly peruse this Privacy Policy alongside any other privacy or fair processing policies we may issue on specific occasions when collecting or processing your personal data. This collective understanding ensures that you grasp the comprehensiveness of how and why your data is employed. This Privacy Policy is intended to complement additional notices and is not intended to supersede them.

1. WHO WE ARE

TIRONA LIMITED ("TIRONA"), a legally registered limited liability company in Cyprus under registration number ΗΕ 293370, TIRONA operates as a Holding of Investments company and also offers financial services, conducting its activities within the European Union region. Our digital presence is represented by the website: ../

For inquiries or clarifications regarding this Privacy Policy, or if you seek detailed insights into the manner in which we employ your personal information, please do not hesitate to contact our team. They will readily direct you to a specialist reachable at info@tirona.eu


2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU

Personal data encompasses any information concerning an individual that permits their identification. We may gather, utilize, retain, and transmit diverse categories of personal data pertaining to you, which we have categorized as follows:

  • Identity Data: This category encompasses personal particulars as they appear on your birth certificate. These include but are not limited to your name, titles, analogous identifying labels, marital status, date of birth, gender. Additionally, it includes other identity-associated data such as passport numbers, identity numbers, or tax identification numbers.
  • Contact Data: Within this category, we incorporate data associated with your residences, correspondence, email addresses, and telephone numbers.
  • Financial Data: This category integrates particulars imperative for payment processing, fraud prevention, and supplementary data connected with transactions to and from you. This may include bank account specifics.
  • Matter Data: Enclosed herein are communications and documents crafted concerning any matter for which we offer representation, whether on your behalf or on behalf of another of our clients.
  • Marketing and Communications Data: Within this classification, we take into account your inclinations concerning receiving information about our firm, services, and events.
  • Technical Data: Comprising information procured during your interactions with our website through the utilization of cookies.
  • Special Categories of Personal Data: In certain cases, we may gather and utilize sensitive personal data during the process of delivering our services to you. This encompasses information encompassing your racial or ethnic origin, political viewpoints, religious convictions, involvement in trade union activities, physical or mental well-being, sexual life, sexual orientation, as well as details related to criminal offenses, genetic, or biometric data.

3. HOW DO WE COLLECT YOUR PERSONAL DATA

We employ diverse methodologies for procuring data from you and pertaining to you, including but not limited to:

  • Direct Interactions: You have the agency to furnish us with your data through electronic means, telephonic communication, postal services, physical meetings, or other avenues. This encompasses personal data imparted during various instances, including:
    • Contacting us through our official website.
    • Supplying Identity, Contact, Financial, and Matter Data upon becoming our client or a prospective client.
    • Providing Identity or Contact Data upon establishing a connection with us.
    • Opting to receive information about our firm, services, and events.
  • Indirect Connections: We may also amass Identity, Contact, Financial, and Matter Data related to you if you are affiliated with one of our clients or are linked to a matter for which our services have been enlisted. Such data can be gleaned from our client, their agents, our agents, or other diverse sources.
  • Automated Mechanisms or Interactions: Through the course of your interactions with our website, we may engage automated mechanisms to capture technical data. This is achieved through the deployment of cookies.

The culmination of these methods ensures a comprehensive collection of data from various touchpoints and contexts.

4. WHY DO WE COLLECT AND PROCESS YOUR PERSONAL DATA

We exclusively utilize your personal data for the subsequent purposes:

  • Contractual Necessity: We engage in the processing of your personal data when it is indispensable for the execution of a contract or for preparatory steps leading up to the formation of a contract. This encompasses, but is not confined to:
    • Registering you as a client.
    • Furnishing services as per your instructions.
    • Receiving services from you or your organization.
    • Executing payment processing, invoicing, and collection activities.
  • Legitimate Business Interests: Your personal data may be processed based on the legitimate interests of our business, notably:
    • Administering and overseeing our relationship with you, encompassing financial recording, audits, and pertinent actions linked to our business relationship. This entails identifying individuals authorized to represent our clients, suppliers, or service providers.
    • Conducting permissible background verifications.
    • Analyzing and enhancing our services, communications, and adherence to internal policies.
    • Managing premises access and security.
    • Safeguarding the integrity of our communication systems and other systems, thwarting security threats, fraud, criminal activities, and malicious endeavors.
    • Fulfilling insurance requirements.
    • Exercising or safeguarding our legal rights, including compliance with court orders.
    • Offering legal guidance and services to our clients.
    • Maintaining a line of communication to keep you apprised of the latest developments, announcements, and pertinent information regarding our services and solutions. This includes briefings, newsletters, events, initiatives, marketing campaigns, and promotional activities. Additionally, we collect data about your preferences to enhance the personalization and quality of our communications with you.
  • Protection of Vital Interests: In circumstances essential for safeguarding the vital interests of employees or other individuals, we process personal data. This encompasses management of incidents, illnesses, accidents, injuries, or emergencies transpiring at our premises. Furthermore, this may entail contacting you or other pertinent individuals in the event of an emergency.
  • Public Interest and Legal Obligations: Data processing is pursued when the task holds a clear legal basis and serves a public interest.
  • Compliance with Legal Obligations: Processing may transpire to comply with legal obligations, encompassing record retention, compliance evaluations, and screening. Instances include tax compliance, anti-money laundering measures, financial and credit evaluations, fraud and crime prevention and detection, and adherence to trade sanctions. This might entail automated cross-referencing of personal data you provide against pertinent databases, as well as communication for identity confirmation. In certain cases, sharing of personal data with third parties, including competent law enforcement authorities, might be necessary.
  • Consent-Based Processing: Your personal data may be processed based on your explicit consent, for reasons such as:
    • Maintaining communication to keep you informed of the latest services, briefings, newsletters, events, initiatives, and related details.
    • Dispatching information regarding client surveys, marketing initiatives, or promotional activities.
    • Collecting information to enhance the personalization and quality of communication with you.

It's pertinent to emphasize that your personal data will not be employed for automated decision-making processes that influence or construct profiles.


OPTING OUT

You have the right to request the cessation of receiving information from us about our firm, services, or events. This can be accomplished by contacting us at info@tirona.eu. Please be aware that if you choose to opt out of receiving such information, your opt-out preference will not extend to personal data that you have provided to us for any other intended purpose.

COOKIES

You possess the ability to configure your web browser to decline all or specific browser cookies or to receive notifications when websites attempt to establish or access cookies. However, it's important to note that disabling or refusing cookies may result in certain portions of our website becoming inaccessible or functioning inadequately.

CHANGE OF PURPOSE

We will exclusively utilize your personal data for the purposes for which it was originally collected, unless a reasonable determination is made that it should be employed for a different purpose that is harmonious with the initial intent. Should you desire an explanation regarding how the processing for the new purpose aligns with the original one, kindly reach out to us.

In the event that we find it necessary to employ your personal data for a purpose unrelated to the original, we will apprise you of this intention and clarify the legal basis that permits us to do so.

It's important to note that there are situations in which we may process your personal data without your knowledge or explicit consent, if such processing is mandated or sanctioned by applicable law.


5. WHO WE SHARE YOUR PERSONAL DATA WITH

There are instances where we may need to disclose your personal data as follows:

  • Within Our Group: We may share your personal data with entities within our group of companies, which includes subsidiaries and affiliated companies. This sharing is carried out to facilitate the provision of services as delineated herein.
  • Third-Party Collaborators: We might share your data with third parties, including legal professionals, advisors, expert witnesses, legal specialists, translators, couriers, and other indispensable entities and subcontractors. Such sharing is essential for the purpose of delivering the services described herein.
  • Client Disclosure: In situations where your personal data has been accumulated in the course of providing services to our client, we may share this data with our client.
  • Service Providers: We may disclose your data to service providers, encompassing IT service providers.
  • Regulatory and Legal Obligations: We may share your data with regulatory bodies, law enforcement agencies, or in compliance with a court order or legal commitment. This may be done to enforce our business terms or protect the interests of our business, staff, and clients.
  • Business Changes: Your data may be shared with third parties in circumstances such as mergers, sales, or restructuring of our business.

We obligate all third parties to uphold the security of your personal data and treat it in accordance with applicable laws. We do not permit our third-party service providers to utilize your personal data for their individual purposes. Their processing of your personal data is restricted to specific purposes and carried out in alignment with our instructions.

6. HOW LONG WE RETAIN YOUR PERSONAL DATA

We will retain your personal data only for the duration necessary to fulfill the objectives for which it was collected. In situations involving a client relationship, we will store your personal data for a minimum period of five (5) years following the cessation of such a relationship.

In establishing the appropriate retention duration for personal data, we assess factors such as the quantum, nature, and sensitivity of the data, the potential risk arising from unauthorized use or disclosure, the objectives of data processing, alternative means to achieve these objectives, and the pertinent legal requirements.

We might extend the retention of data for extended periods due to legitimate business interests, legal or regulatory duties, or for safeguarding vital interests, yours or others’.

In specific scenarios, you retain the right to request the deletion of your data. For further insight, please refer to the details below.

7. WHAT LEGAL RIGHTS YOU HAVE OVER YOUR PERSONAL DATA

In specific situations, you possess the subsequent rights regarding your personal data:

  • Right of Access: You hold the right to obtain access to your personal data.
  • Right to Rectification: It is our commitment to maintain the accuracy, currency, and completeness of your personal data.
  • Right to Erasure: You retain the right to request the deletion of your personal data if there is no legitimate reason to sustain its processing.
  • Right to Object: If we rely on a legitimate interest (or that of a third party) for processing, and your unique situation justifies your objection on the basis that it infringes upon your fundamental rights and freedoms, you have the right to object.
  • Right to Restrict Processing: You may request the temporary suspension of processing your personal data.
  • Right to Data Portability: You have the right to demand the transfer of your personal data to yourself or a third party.
  • Right to Withdraw Consent: You possess the right to retract your consent at any time, if our processing relies on your consent.

Should you wish to exercise any of the aforementioned rights, kindly contact us at info@tirona.eu.

WHAT WE MAY NEED FROM YOU

To validate your identity and ensure your entitlement to access your personal data (or exercise any other rights), we may require specific details from you. This serves as a security measure to prevent unauthorized disclosure of personal data. We may also communicate with you to request additional information pertaining to your request in order to expedite our response.

Our intention is to reply to all valid requests within a month's time. However, in instances of heightened complexity or numerous requests, the response period may extend beyond a month. If such an extension occurs, we will duly inform you and provide updates accordingly.

8. ADDITIONAL INFORMATION

THIRD-PARTY LINKS

Our website may feature links to external third-party websites. Clicking on these links could enable third parties to gather or share information about you. We strongly advise you to meticulously review the privacy policies and terms and conditions of every website you visit.

It is essential to note that we lack control over these third-party websites and consequently bear no responsibility for the content, privacy policies, or practices associated with any third-party websites, products, or services.

CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

Although the majority of alterations are anticipated to be of minor nature, TIRONA LIMITED retains the prerogative to periodically modify this Privacy Policy, exercising this right solely at its own discretion. We encourage visitors to regularly monitor our website tirona.eu for any alterations to this Privacy Policy. Your continued utilization of our website subsequent to any revision in this Privacy Policy will signify your acknowledgment of such revisions.

It remains pivotal that the personal data we hold about you remains accurate and current. Kindly ensure that you apprise us of any changes to your personal data during the course of your relationship with us.