Pamboridis LLC (“Pamboridis LLC”, “we” “us” or “our”) values your privacy and is committed to protect all personal data it collects in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Cyprus personal data laws and regulations.

This privacy policy (the “Privacy Policy”) is addressed to you (“you”, “your” or “yours”) who provide personal data to us when: 

  • you visit our website at www.pamboridis.com (the “Website”) 
  • you submit an enquiry via the Website
  • you apply for employment via the Website

It is important that you read this Privacy Policy carefully. By visiting this Website and by completing and submitting the web-forms uploaded in the Website, you are deemed to have read and understood this Privacy Policy. If you choose not to provide any personal data requested we may not be in a position to respond to your queries, process your application for employment or provide full functionality of the Website. 

This Privacy Policy should be read together with our Terms & Conditions

Who is responsible for your Personal Data (Data Controller)

Pamboridis LLC, a lawyers’ limited company incorporated under the laws of the Republic of Cyprus and regulated by the Cyprus Bar Association, is the owner of the Website and the data controller of your personal data. We have the responsibility of the collection, management, handling and processing of your personal data collected through your visit to the Website.

You can contact us at:
Address: Pamboridis House, 45 Digeni Akrita Avenue, CY-1070, Nicosia, Cyprus
Email: info@pamboridis.com
Tel: +357 22 75 25 25

What Personal Data we collect

When you visit and browse our Website

  • Internet Protocol (IP) address
  • Name of your internet service provider (ISP) depending on the configuration of your ISP connection
  • Date and time of your visit to our Website
  • Pages which you have accessed (where applicable)
  • Number of times you visit our Website within any month
  • File URL you look at and information relating to it
  • Operating system which your computer/device uses and the browsing history

When you submit an enquiry via the Website

  • Name, surname, phone number and email address
  • Information you voluntarily submit to us

When you apply for employment via the Website

  • Name, surname, phone number, email address and CV (academic qualifications, professional background, job title and any other information included in the CV)
  • Reference Letters
  • Any other information relevant to potential recruitment by us, submitted by you via the exchange of email(s), interview(s) or telecom(s) e.g. copy of your ID or passport, residential address, social insurance number. 
  • Information you voluntarily submit to us

General

We may request and process additional personal data, provided always that we are legally entitled do so. If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the time we collect it. 

In connection with the provision of our services to you we may on certain occasions need to ask for special categories of personal data (sensitive data) such as information about your health, disability or ethnicity. If we collect any sensitive personal data from you to use it for reasons other than based on the exceptions provided under the GDPR, we will obtain your explicit consent prior to the collection. You have the right to revoke your consent at any time however any processing prior to the receipt of such revocation will not be affected. 

If you intend to provide us with personal data about other individuals you must provide a copy of this Privacy Policy directly to them.

The purposes of processing your Personal Data
What legal bases we use

When you visit and browse our Website

  • for allowing you to safely browse and use our Website
  • for providing you the best possible browsing experience 
  • for delivering relevant Website content and updates to you 
  • for measuring and understanding your Website experience and improve our Website 
  • for measuring the effectiveness of the contents we provide to you
  • for improving our Website using data analytics 

The processing is based on our legitimate interest (Article 6 (1) (f) GDPR)

When you contact us for an enquiry via the Website

  • for allowing you to contact us
  • for responding to your enquiries 
  • for replying to your requests for legal or administrative/nominee services

The processing is partly based on our legitimate interest (Article 6 (1) (f) GDPR) and partly necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract or generally in the context of any other dealings we may have with you (Article 6 (1) (b) GDPR)

When you apply for employment via the Website

  • for allowing you to submit an application for employment with Pamboridis LLC
  • for processing your application as a candidate for employment
  • for assessing your suitability for the position you have applied
  • for ensuring equal opportunities to all potential employees of Pamboridis LLC

The processing is necessary to take steps at your request prior to entering into a contract or generally in the context of any other dealings we may have with you (Article 6 (1) (b) GDPR)

From where we collect your Personal Data

When you visit and browse our Website 

We automatically collect Technical Data about your equipment and browsing actions. We collect this personal data by using cookies. Please see the Cookies section below for further details

When you contact us for an enquiry via the Website

We collect and process the personal data you have voluntarily and directly submitted to us

When you apply for employment via the Website

We collect and process the personal data you have voluntarily and directly submitted to us or from third parties e.g. individuals, such as your ex-employers or ex-colleagues, who may give us a reference or a background related to your previous employment, or from publicly available sources such as social media platforms e.g. LinkedIn

With whom we share your Personal Data

We may disclose and share the personal data we collect or you share with us with third party recipients if:

  • we are legally required to do so
  • we are authorised under our statutory obligations
  • we are authorised under our contractual obligations
  • you have given us your consent

When sharing your personal data with third parties, we comply with our legal and regulatory obligations in relation to your personal data and maintain appropriate safeguards in place, to include ensuring that all third party recipients have access to your personal data on a strictly “need to know basis” so that they can fulfil the obligations they have undertaken against and properly provide their services to us, that such third party providers process your personal data exclusively on our behalf and according to our instructions, that such persons will comply with the GDPR and the Cyprus personal data laws and regulations and, where applicable, maintain appropriate safeguards in place by entering into “data processing agreements ” pursuant to article 28 of the GDPR.

Your personal data may be shared with the following third party recipients:

  • Individuals working with us e.g. our employees
  • External service providers assisting in our day to day business e.g. courier providers
  • External service providers assisting in implementation of our procedures e.g. IT systems or software or support service providers or website developers
  • External collaborators e.g. banks, legal counsels, accountants, auditors, translators
  • Our wholly owned subsidiaries
  • Supervisory and other regulatory authorities who have power to request information from us e.g. Cyprus Bar Association
  • Government Departments and Public Authorities e.g. the Tax Department, the Social Insurance Department, the Civil Registry & Migration Department, the Department of Registrar of Companies & Intellectual Property and Criminal Prosecution Authorities
  • Fraud prevention agencies
  • Credit institutions and other financial institutions
  • Third parties engaged in the course of the services we provide to clients such as outside counsel, arbitrators, mediators, clerks, witnesses, cost draftsmen, court, opposing party and their lawyers, document review platforms and experts such as tax advisors and auditors 

The above is a non-exhaustive list of persons and entities with whom we might share your personal data with. There may be other instances and persons to whom we may disclose your personal data as applicable. 

Transfer of your Personal Data outside the EEA 

We do not transfer your personal data to countries outside the EEA (European Economic Area)

EEA: EU Member States plus Iceland, Liechtenstein and Norway

Exceptionally, your personal data may be transferred to countries outside the EEA if:

  • this is required for fulling our contractual obligations
  • you have granted us your consent
  • this is required by law

Processors in countries outside the EEA, which are not considered ensuring an adequate level of protection of personal data by the EU Commission or a national data protection authority (the so called “Unsafe Third Countries”) are obliged to comply with the data protection level in Europe and provide appropriate safeguards in relation to the transfer of your personal data in accordance with article 46 of the GDPR. Where we use agents/service providers located in such Unsafe Third Countries we will ensure that they (i) apply the level of protection required under the GDPR and (ii) act in accordance with our written instructions and our policies and standards. Any cross-border transfer of your personal data outside the EEA will be performed by us in line with the applicable provisions of the GDPR and the Cyprus personal data laws and regulations, such as by using the European Commission’s standard contractual clauses.

For how long we keep Personal Data (Retention Period)

In general we retain your personal data for the period necessary to fulfil the purposes for which it was initially collected. We may keep your data for longer than the period referenced below if this is required or permitted by law or is necessary for us to defend our legitimate interests such as to respond to or conduct prospective or actual legal claims or proceedings or achieving the purposes for which they have been collected. Where we no longer require your personal data we will ensure that it is either securely deleted or destroyed or stored in a way which means it will no longer be used by us.

When you visit and browse our Website

For the retention period of cookies please refer to the Cookies section below. 

When you to contact us for an enquiry via the Website

The personal data submitted with the web-form for an enquiry will be retained and securely stored by us during the period of our relationship, correspondence and other dealings and for an extended period of seven (7) years thereafter.

When you apply for employment via the Website

The personal data submitted for a job application will be retained for the duration of the recruitment process and in the case of unsuccessful application will be removed and deleted at the latest after we have taken our final decision, unless you give us your consent in writing to retain your personal data for the purposes of possible future employment with Pamboridis LLC.  

How we secure your Personal Data

Pamboridis LLC is committed to ensuring that your personal data is and remains secure and confidential.  In order to prevent unauthorised access, use or disclosure of your personal data, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data that we collect.  Our security technologies and procedures are regularly reviewed to ensure that they are up to date and effective. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy, the GDPR and the Cyprus personal data laws and regulations. 

The personal data you provide to us is stored on our secure local servers and are protected by access codes and firewall. We use Symantec Endpoint Protection to protect disks, files and folders. For the transmission of information via emails we use Microsoft 365. Unfortunately, the transmission of information via the internet is not completely secure and there cannot be assurance of absolute protection. While we take reasonable steps to protect all information submitted to us and received by us in accordance with the Privacy Policy, we cannot, in any event, guarantee the security of any personal data transmitted to us via e-mail and, in general, through the internet, and as such any transmission is at your own risk.

In case we keep your personal data in paper form your personal data is stored in designated secure spaces within our premises where no unauthorised access is permitted. 

All of our partners, employees, consultants, workers and data processors, who have access to, and are associated with the processing of your personal data, are obliged to respect the confidentiality and security of such personal data and comply with the GDPR and the Cyprus personal data laws and regulations. 

Cookies

Cookies are very small text files containing very small amounts of information which are placed and stored on your device when you visit the Website to provide you with access to various functions of the Website. Cookies are then sent back to the Website on each of your subsequent visits to the Website. 

This Website uses strictly necessary cookies only, which are essential and mandatory to ensure the basic operation of the Website, such as navigating and submitting web-forms. We are not required to obtain your consent for the strictly necessary cookies we use.

The Cookies we use:

NameExpirationPurposeType
wordpress_[hash]30 DaysStores user authentication informationSession Cookie
daextlwcn-*30 DaysStores the user's cookie consent state for the current domainSession Cookie

How to Avoid Cookies

If you wish to avoid the placement of cookies on your device, you can control or delete cookies by changing the settings in the web browser you are using. In such a way you can:

(a) set the browser to automatically not allow the download and installation of cookies

(b) delete all cookies that have been previously installed on your device. 

However, you may need to set some preferences yourself each time you visit the Website and some core functions of the Website may not work. 

 

Third Party links

The Website may include links to third-party websites. Clicking on those links 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 policy. When you leave our Website, we encourage you to read the privacy policy of every other website you visit.

What rights do you have regarding your Personal Data

You have the following rights exercisable any time free of charge:

  • Right of Access: You have the right to request access and receive information from us regarding the processing of the personal data we hold about you (Article 15 of the GDPR)
  • Right to Rectification: You have the right to request and obtain from us without undue delay the rectification of inaccurate or incorrect personal data we hold about you (Article 16 of the GDPR)
  • Right to Erasure: You have the right, in the event that the requirements specified in article 17 of the GDPR have been met, to request the erasure of the personal data we hold about you. Accordingly, you may request the erasure of your data, for instance, if it is no longer necessary for the purposes for which it was collected. Furthermore, you can also request erasure if we process your data on the basis of your consent and you withdraw this consent (Article 17 of the GDPR)
  • Right to Restriction: You have the right to request the restriction of the processing of the personal data we hold about you if the requirements specified under article 18 of the GDPR have been met. This is the case, for example, if you dispute the accuracy of your personal data. You may then request that processing is restricted for as long as it takes to examine the accuracy of your personal data (Article 18 of the GDPR)
  • Right to Data Portability: Provided that the data processing is based on your consent or on the fulfilment of a contract and that it is also carried out using automated processing, you have the right to request and receive the personal data we hold about you in a structured, common and machine-readable format and to forward it to another data controller (Article 20 of the GDPR)
  • Right to Object: If processing is based on our legitimate interest, you have the right to object to the processing of the personal data we hold about you if you believe your fundamental rights and freedoms outweigh our legitimate interests (Article 21 of the GDPR)
  • Right to Withdraw Consent: If we rely on your consent (or explicit consent) as our legal basis for processing the personal data we hold about you, you have the right to withdraw that consent at any time. However, the withdrawal of your consent (or explicit consent) shall not affect the lawfulness of processing based on such consent before its withdrawal (Article 7 of the GDPR)
  • Right to Raise Concern: You may exercise your above rights or contact Pamboridis LLC to raise any concerns or request information on the processing of the personal data we hold about you by contacting our Data Protection Officer (DPO) at the details provided below (Article 38(4) GDPR)
  • Right to lodge a complaint: If at any case, you are of the opinion that we infringe your privacy, you have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection of Cyprus:
    Address: Iasonos 1, 1082 – Nicosia – Cyprus
    Box 23378, 1682 – Nicosia – Cyprus
    Tel:       +357 22 81 845 60
    Fax:        +357 22304565PO 
    Email:   commissioner@dataprotection.gov.cy  
    You may find more information at www.dataprotection.gov.cy

Contact Us 

Your point of contact for issues related to your personal data in general and for exercising your rights is our Data Protection Officer (DPO). You may contact our DPO either by email or by post: 

Address: Pamboridis House, 45 Digeni Akrita Avenue, CY-1070, Nicosia, Cyprus

Email: info@pamboridis.com

We will endeavour to respond to any request as soon as possible and no longer than 30 calendar days from the receipt of the request. In case where we will not be able to respond to your request within the aforementioned time period or in case your request is rejected, we will inform you accordingly explaining the reasons for any delay or for rejecting your request. 

Change of this Privacy Policy

We reserve our right to amend this Privacy Policy from time to time and any changes will become effective when we upload the revised Privacy Policy to this Website. We will reasonably endeavour to notify you when we make changes to this Privacy Policy and we will amend the revision date at the bottom of this page. We do however encourage you to review this Privacy Policy periodically so as to always be informed about how we process and protect your personal data. 

Last updated October 2023

Have Questions?

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