1. The information we collect and how we use it
When you register for any of our services, we may require details including:
- Last name and first name
- Company name and your position
- VAT number
- Address details
- Telephone and fax numbers
- Email address
We gather this information to allow us to process your registrations and any orders you make through our websites. The relevant information is used by us to communicate with you on any matter relating to the conduct of your account and the provision of our services in general.
We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us develop the website, and we may provide such aggregate information to third parties. These statistics will not include any information that can be used to identify any individual.
We may also wish to provide you with information about special features of our website or any other service or products we think may be of interest to you. If you would rather not receive this information, please send an email message to info@infocreditgroup.com.
We may automatically collect technical information when you connect to our site that is not personally identifiable. This includes, for example, the type of Internet browser you are using, the type of computer operating system and the domain name of the website from which you are linked to our site.
Within the scope of the provision of our services to our clients, we will come across personal data of individuals who are usually the subject matter of the service we offer to our clients. Through this statement, we inform those individuals that their data will be collected and processed for the purpose of executing our obligation to our clients. This data will be safely processed and stored, and the data subjects have the same rights as all other individuals whose data we process as described in Section 7.
2. For which purposes do we collect personal data?
Except for cases where we provide services directly to you, Infocredit Group Ltd processes data so that it can supply commercial data about organisations to other organisations. The purpose of this processing is to enable businesses to manage their financial risks, protect against fraud, know who they are doing business with, meet compliance and regulatory obligations, and better understand organisations, industries and markets.
Consequently, we collect information on businesses and other relevant information in order to assess risk. This information includes, for example:
- Registration details (registered name, registered address, registration number, etc.)
- Director, secretary and shareholder information (name, surname, identity card / passport / ARC number and issuing country, address, occupation, nationality, date of birth, date of appointment, information on shares held, position held)
- Capital (issued, number of shares, nominal value, etc.)
- Payment records and charges (current and historic)
- Negative information and bankruptcies of the entity and related legal entities
- Financial statements (when available)
- Credit scoring assessment based on financial and non-financial variables
- Company operational histories, subsidiaries, affiliates, and lines of business
- Business compliance information from public-source government and professional records, media and business publications
- Newspaper and media reports of criminal convictions
- Bankruptcy information as retrieved from the Official Receiver
Infocredit does not seek to collect any information in relation to a European resident’s race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic or biometric data.
3. Our data sources
Our data originates from public and other sources, including:
- Public sector information (e.g. company registrars and the Official Receiver)
- Governmental and administrative public records such as business registrations, company filings, court and bankruptcy filings
- Organisations providing information directly to us
- Creditors and suppliers of an organisation
- Regulatory bodies and law enforcement agencies
- Media sources
4. Why do our clients request data from us?
4.1 Credit risk management and assessment
Credit risk management is the practice of determining creditworthiness — assessing new and existing customers for their financial health, which can indicate their ability to pay on time. It is important that suppliers perform due diligence to manage the risks that come with extending business credit.
4.2 Anti-money laundering information for prospective clients
In Cyprus and the other jurisdictions in which we operate, laws and regulations are designed to combat money laundering. Broadly, money laundering can arise if a person acquires, retains, transfers, uses or controls the proceeds of a crime or the benefit of a criminal activity. References to money laundering include references to terrorism.
In order to fulfil their obligations, our clients are obliged to verify the identity of new clients, and in certain circumstances existing clients. Their internal requirements may also require background checks on new or existing clients. These may necessitate verification of the identity and good standing of clients, one or more of their directors, employees or other representatives, and shareholders, beneficial owners, management, directors or officers, and possibly including evidence of the source of funds. In these cases we may request copies of evidence of identity from our client to assist in fulfilling the investigation.
5. Who do we share this information with?
- Customers — businesses and organisations with whom we enter into agreements to licence or access our data. Our customers enter into agreements or licences because they wish to manage their financial risks, protect against fraud, know who they are doing business with, meet compliance and regulatory obligations, better understand organisations, industries and markets, or carry out direct marketing.
- Resellers — we licence information to authorised resellers and third-party businesses for reselling.
6. Grounds of processing
In legal terms we process personal data under the ground of “legitimate interest” and “third party legitimate interest”. Infocredit’s legitimate business interest is the supply of commercial data. The purpose of this processing is to enable businesses to manage their financial risks, protect against fraud, know who they are doing business with, meet compliance and regulatory obligations, and better understand organisations, industries and markets.
7. Our use of cookies
When you view one of our websites, we may store information on your computer. This information will be in the form of a “cookie” or similar file and can help us in many ways. For example, cookies allow us to tailor our website to better match your interests and preferences. With most Internet browsers, you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions.
8. Updating your details
If you believe that any information provided to us or included in our database is not up to date, please contact us at info@infocreditgroup.com in order to proceed with an update.
9. Your consent
In case information is provided to us directly by you through our webpage with the submission of your information, you consent to the use of that information as set out in this policy. If we change our privacy policy we will post the changes on this page so that you may be aware of the information we collect and how we use it at all times. Continued use of the service will signify that you agree to any such changes.
10. Events registration
To register as a delegate for an event you must complete a registration form. During registration you are required to give your contact information (such as name, address, phone number and email address). This information enables us to process and fulfil your enrolment online so that we can contact you about the events for which you have expressed interest. Optionally, you may provide demographic information (such as company name and position). If you do provide such information, we are able to use it to provide a more personalised experience on our website.
11. Your reinforced rights
Infocredit has taken appropriate measures to provide any information relating to your rights as well as the exercise of these rights. Under Chapter III of the GDPR you have the following rights:
I. Transparent information
You have the right to be provided with your data freely and in an intelligible and easily accessible form. Following your request, Infocredit shall provide information without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. Infocredit will inform you of the reasons for any delay.
II. Information where data is collected from you
You have the right to know the contact details of the data controller, the contact details of the Data Protection Officer, the purposes of processing, the legal basis for processing, the recipients or categories of recipients of the personal data, and where applicable the fact that the controller intends to transfer personal data to a third country.
III. Right of access
You have the right to request and receive a copy of your personal data undergoing processing. For any further copies requested, Infocredit may charge a reasonable fee based on administrative costs.
IV. Right to rectification
You have the right to obtain from Infocredit without undue delay the rectification of inaccurate personal data concerning you. Note that we cannot amend the public register itself; corrections to a company record must be filed with the Registrar, after which our copy is updated.
V. Right to erasure ('right to be forgotten')
You may ask for the erasure of your personal data where it is no longer necessary for the purposes for which it was collected. Where Infocredit retains and processes personal data to comply with a legal obligation, we may object to such a request and keep the data required to comply with that obligation.
VI. Right to restriction of processing
You have the right to restrict processing where the accuracy of your data is contested, where the processing is unlawful, or where there is pending verification as to whether the legitimate grounds of Infocredit override your rights. For data necessary to comply with a legal obligation, Infocredit may object to the restriction.
VII. Right to data portability
You have the right to receive the personal data you have provided to Infocredit in a structured, commonly used and machine-readable format, and to transmit those data to another controller without hindrance.
VIII. Right to object
You have the right to object to the processing of your personal data. Because Infocredit lawfully processes such data under Article 6(1)(c) of the GDPR for compliance with legal obligations or under Article 6(1)(f) for legitimate interests, the right to object may be limited where the processing remains necessary.
IX. Automated decision-making and profiling
You have the right 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.
You can exercise your reinforced rights by contacting us at info@infocreditgroup.com.
12. Data protection responsibilities
We process and store all personal data in line with EU Data Protection Legislation. Personal data is utilised for registration purposes only and is not sold or forwarded to any third parties without your consent.
For the purposes of this Privacy Policy we act as “data controllers” when we determine the purposes for which and the manner in which any personal data are, or are to be, processed. Furthermore, we act as “data processors” when we obtain, record or hold the information or data, or carry out any operation or set of operations on the information or data.
For any further information you need with regard to Data Protection, please contact our Data Protection Officer:
A. & E. C. Emilianides, C. Katsaros & Associates LLC
192 Ledras, 3rd Floor
1011 Nicosia, Cyprus
Tel: +357 22 676752
Fax: +357 22 676754
Email: DPO@infocreditgroup.com