Data Collection & Processing
The types of data we may collect about you mainly depends on the relation that we have with you, meaning whether you are one of our clients (or a prospective client), a browser of our website or a recipient of our news and insights via email.
This data may include your personal and contact details that you voluntarily provide to us, for example when you contact us, sign up to our mailings list, submit an application to work with us, when you are a contractor or a supplier to us, when you visit our offices, and when you exercise any of your rights in accordance with the applicable privacy laws.
In the case that you are a client of ours, or a prospective client, the data we collect focuses on information which is necessary for performing the services you have requested from us, including the performance of our contractual obligations to you, or required to be collected for the purposes of our compliance with any legal, regulatory, contractual, tax, accounting or reporting requirements, such as data collected during our background checks to accept you as a client in accordance with the applicable Know-Your-Client (KYC) and anti-money laundering procedures, or your details relating to the payment of our invoices. We also use your personal data in our correspondence with you, which may relate to the services we provide to you or to services which we consider of interest to you, or to ensure that our records are kept accurate and up-to-date, and to ensure your safety and security when you visit our offices.
In the case that you submit an application to work with us, you will voluntarily be providing us with documents necessary to process your application, the most important being your curriculum vitae, which typically includes your contact details, employment history, educational background and references, along with any other information you choose to share with us in order to assess the particular candidate.
In the case that you subscribe to hear from us (i.e., subscribe to our mailings list), you provide us with your consent to collect and use your personal data which relates to your marketing preferences, including your contact details in order for us to contact you via your preferred communication method.
Each time you visit our website, we may automatically collect the following information:
(i) web usage information (e.g., IP address), your login information, browser type and version, time zone setting, operating system and platform;
(ii) information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from our website (including date and time); time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs); and
(iii) location, device and demographic information (Google Analytics provides age range and gender information. Find out more about how Google collects demographic data).
We will retain any personal data collected for as long as reasonably necessary based on the purposes for which it was collected as may be applicable in each case, for example, as long as we continue to provide you and/or your business with our services, assess your application to work with us, for the purposes of our compliance with any legal, regulatory, contractual, tax, accounting or reporting requirements, as well as for as long as we continue to have your consent to retain and process your personal data, for example, by continuing to be subscribed to our mailings recipients list. We may retain your personal data for a longer period of time 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 collect and process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We implement generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration or destruction. We require all staff members and/or external associates to keep personal data confidential and only authorised persons have access to this information. Nevertheless, you will appreciate no information system can be entirely secure, therefore we cannot guarantee absolute security of your information nor be responsible for the security of any information you send to us over networks outside our control.
In general, we do not share your personal data with third parties unless we have a lawful basis for doing so.
We rely on third-party service providers to perform a variety of services on our behalf, such as website hosting, electronic message delivery and payment processing. This may mean that we have to share your personal data with these third parties. When we share your personal data in this way, we put in place appropriate measures to make sure that our service providers keep your personal data secure.
Other situations in which we may disclose your personal data to a third party, are the following: where permitted by law, to protect and defend our rights and property; to fulfil our contractual obligations to you in respect of the services you have requested us to provide to you for example with regard to various outsourced services; and when required by law and/or competent public authorities.
Our digital content is controlled from and stored in Cyprus or other countries where our affiliated businesses or associates operate. It is possible that personal data we collect from you may be transferred, stored and/or processed outside the European Economic Area if we are required by any applicable laws or regulations or upon your consent to do so. Such transfers will be made on the basis of specific requirements, including the model clauses approved by the European Commission (EC) for transfers from EU controllers to non-EU controllers, which may be found on the EC website.
Right to information. You can obtain further information on the personal data which Trojan Economics stores and processes about you by sending an email to email@example.com stating this request.
Right to access and receive a copy of your personal data and data portability. You may access and request to receive a copy of your personal data in a structured, commonly used and machine-readable format and, if technically feasible, you may request that the personal data is transmitted directly to another company or person acting as a data controller. Please send an email to firstname.lastname@example.org stating this request.
Right to rectification and restriction of processing. You may request that your personal data is rectified or restrict the processing of your personal data. If you wish to have your data rectified or restrict the processing, please send an email to email@example.com stating this request.
Right to be forgotten. You may request the erasure of the personal data we hold about you without undue delay, by sending an e-mail to firstname.lastname@example.org stating this request.
Right to object. You may object to your personal data being processed. If you wish to object to the processing of your personal data, please send an email to email@example.com stating this request.
Right to withdraw consent. You may withdraw your consent to the processing of your personal data, by sending an email to firstname.lastname@example.org stating this request. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data and, subject to your instructing us to do so, we will erase your personal data.
Automated individual decision-making, including profiling. You may request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, by sending an email to email@example.com stating this request.
Right to make a complaint. If you have any complaints about Trojan Economics’ processing of your personal data, you may contact the Office of the Commissioner for Personal Data Protection of the Republic Cyprus.
Further guidance may be obtained from the Office of the Commissioner for Personal Data Protection of the Republic Cyprus.
Links to other websites
If you consent to us contacting you, we will always aim to be respectful, relevant and appropriate. If at any time you do not think that we have complied with this, please contact us straight away to let us know. You may contact us through the Contact Us section of our website, or as follows:
: +357 22560175
: PO BOX 12906, 2254 Nicosia, Cyprus
You also have the right to make a complaint to the Office of the Commissioner for Personal Data Protection of the Republic Cyprus, which is the competent authority for matters relating to personal data protection in Cyprus.
: +357 22560175
: PO BOX 12906, 2254 Nicosia, Cyprus