Privacy Policy

PRIVACY POLICY – TOPSMART

Thank you for visiting the website (“Site”) of Topsmart Investments AIFLNP V.C.I.C. LIMITED (“Topsmart”). For the purposes of this Privacy Statement, Topsmart will also refer to its partners, related affiliates and their partners, members, directors, officers and employees. Topsmart is committed to protecting your privacy. Thus, the purpose of this Privacy Statement is to help you understand whether and how Topsmart collects and uses information about you when you visit and/or use the Site, as well as when you decide and you are accepted to investin Topsmart. The processing of personal data is effected in accordance with Regulation (EU)
2016/679 as well as all other applicable laws concerning data protection or privacy (“Data
protection legislation”).

For the purposes of Data Protection Legislation the data controller is Topsmart, meaning that Topsmart determines the purposes and means of the processing of your personal data. By visiting the Site, you agree to this Privacy Statement. This Statement concerns only the said Site and not any website to which this Site may link and thus Topsmart cannot bear responsibility for the protection of personal data that you provide in these websites.

What categories of information does Topsmart collect about you

Certain pages, information and/or materials provided via the Site can only be accessed upon
registration and/or the provision of certain personal information, including but not limited to name, telephone/mobile phone number, home address, email address, passport/ID card, other “know your client” requirements (such as place of birth, profession, current income and expenses) etc. Such information is referred as personal data. Further, personal data is required if you wish to submit an enquiry and/or comments via the relevant webpage of the Site. The personal data to be collected will depend on the kind of services Topsmart will provide you with. By providing any personal data to Topsmart, you consent to its use as prescribed in this
Statement.

Further, every time you visit the Site, some information is being collected automatically, such as IP address or other device identifier, the type of used device, your browser type and language, the computer’s operating system, information about full URLs, clickstream to, through and from our Site (including date and time), methods used to exit pages, duration of visits to a page, page interaction information (e.g. clicks, scrolling and mouse-overs), platform type, location data. This
information is not related to your personal data since it is anonymous and is used solely for security and statistic purposes, aiming to improve the Site.
Topsmart may also use cookies, a piece of data stored on the user’s computer hard drive containing information about the user’s internet use, tracking the patterns of his/her behavior, once accepted by him/her. Cookies allow web applications to tailor their operations to the user’s needs by collecting data regarding the user’s preferences. Topsmart uses cookies exclusively for statistical analysis purposes and afterwards this information is removed from the system.
Cookies contribute to the improvement of our Site and the services we provide, tailoring them to our customers’ needs. You can decline cookies through the activation of the setting on your browser. However, in this case you may have limited access in some areas of the Site.

How and why does Topsmart collect, process and disclose Personal Data

Topsmart collects and processes different types of personal data which are received by its (potential) clients via themselves, the Site, online form, email, lawfully from third parties, eg. other service providers and/or from publicly available sources, such as Department of Registrar of Companies and the bankruptcy archive. Topsmart collects, processes and discloses your personal data in order to meet its legal, statutory, contractual, accounting and tax obligations and continue the provision of its services, this including the possibility of sharing the said data with Topsmart’s third parties who support its information technology, analytics and search engine providers, agents, consultants and service providers assisting in the operation of its business and who are bound by security and confidentiality rules. Tospmart will collect exclusively the necessary personal data from you and will not process any such data unlawfully. It is noted that although the provision of your personal data to Topsmart is not obligatory, the latter will not be able to offer its services to you through the creation of a contractual relation
without the provision of this information. In accordance with Data protection legislation Topsmart may collect and process personal data
since these are:
– performed following your explicit consent; or
– required for the pursuit of the legitimate interests of Topsmart, namely the administrationand operation of its business, compliance with its legal obligations, storing and disclosure of information where required, evaluation, development and improvement of its services and provision of marketing materials and newsletters; or
– required for the performance of a contract with you; or
– required in order to comply with a legal obligation to which it is subject.
In case of special categories of data, the processing is performed: (i) following your explicit consent (ii) if you have made this data manifestly public; or (iii) if it is required for establishing, exercising or defending legal claims.
Further, it is noted that by providing Topsmart with your personal data, you consent this information to be transferred to every country (including non-European Economic Area countries with less stringent data protection rules) where Topsmart has business operations or service/analytics/information technology providers and agents, as well as when required or permitted by the applicable legislation and for the purposes outlined in the present Statement.
However, in such a case contractual arrangements are made in order the processing of personal data to be aligned with the Statement as well as our confidentiality and security policies. Further, measures are taken for the lawful transfer of the personal data outside the EU, including the execution of an agreement based on the European Commission approved standard contractual clauses on the transfer of personal data outside the EU.

Your rights

According to Data protection legislation, you have the right to be notified when there is personal data breach that could result in a high risk to your personal data. You are also entitled to be informed about the processing of your personal data that Topsmart holds, move your personal (right to data portability), access and request a copy of this personal data, receive your personal data in a structured, commonly used and machine-readable format, update your personal data, have any inaccurate information corrected or any part or all of such information deleted in certain circumstances, withdraw the consent given to Topsmart regarding the processing of your personal data, request Topsmart to stop sending you marketing messages and newsletters, including profiling to the extent that it is related to such direct marketing, and restrict or object to the use of your information in certain circumstances. Further, you have the right not to be subject to a decision based exclusively on automated processing, including profiling, which produces legal effects related to you or similarly affecting you in a significant extent, subject to
certain restrictions. To do so, please send your request to topsmart@topsmartinv.com, to which we shall respond within a reasonable timeframe not exceeding one month.
In particular, with regards to the right to object, you are entitled, based on your particular circumstances, to object to processing of your personal data on grounds relating to either the performance of a task carried out in the public interest or in the exercise of official authority vested in Topsmart or relating to the pursuit of the legitimate interests of Topsmart or of a third party, including profiling based on those provisions. In such case, Topsmart shall stop processing the personal data unless the former demonstrates compelling legitimate grounds for the processing overriding your interests, rights and freedoms or for the establishment, exercise
or defense of legal claims.
If Topsmart receives a request from you to exercise any of the above rights, the former may ask for the verification of your identity before acting in accordance with your request so as to avoid disclosure to non-related persons. In the event you wish any further information and/or clarification of any kind, please do not hesitate to contact us.

Security

The Site takes every precaution to protect its users’ information. However, since there are not perfect security systems and policies Topsmart will not be held liable and/or responsible for any damages, losses or causes of action as a consequence of or in relation to the disclosure of the user’s/visitor’s personal data. Further, Topsmart shall not bear liability for any damage of third parties caused by actions or omissions of the users of the Site which are unlawful and/or against the fair practice and public order. It is also clarified that communicating with Topsmart via the submission of an enquiry and/or comments via the relevant webpage of the Site, or via email, is not absolutely safe. Thus, it is recommended not to include sensitive personal data in these messages to Topsmart. Please bear in mind that Topsmart staff will never ask you to provide them with your username and/or password. Thus treat this information confidentially and avoid sharing them via email or phone.

Retention of information

Topsmart retains your personal data in a form permitting your identification for as long asnecessary for the purposes described in the present Statement or required by law. To this end, Topsmart frequently reviews its files and records to ensure that they are accurate, updated and still necessary. Your personal data may be stored for longer periods so long as they will be processed only for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in line with Article 89(1) of the Regulation (EU) 2016/679, the rest Data protection legislation, as well as the implementation of the proper technical and
organisational measures provided therein for safeguarding your rights and freedoms.

Questions and Complaints

In case of any concerns or questions regarding the security of Topsmart’s Site, Topsmart’s Privacy Policy or any personal data collected from you, please do not hesitate to contact us via email at topsmart@topsmartinv.com. Additionally, in case you may have any concerns about the handling of your information by Topsmart, you are entitled to lodge a complaint to the Data Protection Commissioner’s Office, the authority which is in charge of the regulation and
supervision of the use of personal date in the Republic of Cyprus.
http://www.dataprotection.gov.cy
1 Iasonos str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy

Amendments to the Privacy Statement

The present Privacy Statement may be revised. Any such amendments will come in force once posted.