This privacy policy covers the responsibilities of IC REALTY LTD with regards to the Data Protection regulation 679/2016/EU.

By visiting this website www.icaifm.com and by contacting IC REALTY LTD as well as by entering into a service agreement with IC REALTY LTD, you confirm that you have read this privacy policy and understood the content. We may therefore collect your personal data as specified in this privacy policy and use this personal data for the purpose as described within this privacy policy.

You’re aware that you can make use of your rights as displayed within this privacy policy at all times.

IC REALTY LTD is a Cyprus based Alternative Investment Fund Manager, licensed and regulated by the Cyprus Securities and Exchange Commission, with the licence number AIFM 24/56/2013.

IC REALTY LTD operates the internet domain www.icaifm.com

The premises of the Company are located at:

4 Annis Komninis Street
Solea Building, Office 202
1060 Nicosia
Cyprus
Telephone: +357 22 026196
Fax: +357 22 026197
Email: info@icaifm.com

At IC REALTY LTD, we treat all individual visitors that enter our corporate website www.icaifm.com, as well as all private individuals that either represent our prospective and / or corporate clients as well as all our private individual clients as Data Subjects in the sense of the Data Protection regulation 679/2016/EU. IC REALTY LTD fulfils the role of the Data Controller with regards to all personal data, which relates to all individual visitors that enter our corporate website, as well as to all individual persons among our clients, including representatives of our prospective and / or existing corporate clients (i.e. representative/s, local management and Universal Beneficial Owner/s).

IC REALTY LTD has appointed a Data Protection Officer (DPO). The DPO remains independent within our corporate structure and has a direct connection to the top level management at IC REALTY LTD. By submission of electronic correspondence to dpo@icaifm.com, you can get in touch with our DPO and submit your request with regards to your personal information.

We understand the importance of maintaining the confidentiality and privacy of your personal information and data. By entrusting us with your information and data, we would like to assure you of our commitment to keep such information private and secure. We have taken measurable steps to protect the confidentiality, security and integrity of your information and data.

IC REALTY LTD collects personal information of our corporate website provided by our website’s server host device and during the course of rendering our regulated services to our clients.

This information collected includes, but is not limited to the following data:

From corporate clients

• Certificate of incorporation
• Certificate of shareholders
• Certificate of registered address
• Resolution of Directors
• Certificate of Incumbency
• Certificate of good standing
• Memorandum and Articles of Association
• Audited financial statements
• Copies of Licenses granted to the corporate entity
• Information on corporate bank account numbers
• Set of contact data of corporate entity
• Set of contact data of employees and / or local management and / or Universal beneficial Owner

From individuals representing a corporate client

• Copy of Passport
• Copy of ID card
• Proof of physical address of an individual
• Information and documents related to an individual’s profession and /or employment
• Criminal record of an individual
• Documents on the financial status of an individual (e.g. non-bankruptcy certificate)
• Professional certificates of an individual’s professional background
• Documents regarding the educational background of an individual
• Documents related to the origin of wealth of an individual
• Contact telephone number(s) related to an individual
• Electronic mail address related to an individual

All sets of personal data related to an individual Data Subject, which is collected by IC REALTY LTD, is used strictly for the purpose of rendering the variety of our regulated services to our prospective and / or existing clients.

This requires internal processing of data in order to perform a functional risk management in the best interests of our clients and in order to install the client accounts respectively.

Our regulated services require also disclosures to external entities, regulatory authorities and governmental bodies as per our organisational structure. Your rights to your personal data remain valid at all times and can be utilised by contacting our DPO by electronic mail services to dpo@icaifm.com

How is your personal data stored and/or retained?

The Company will only use, store, process and handle the client’s Personal Information and Data in accordance with Data Protection regulation 679/2016/EU. Access is strictly limited to the authorised personnel to perform a specific task or duty only.

This means we retain hard copies of personal data related to individual persons (employees, private clients and/or representatives or UBOs of corporate clients) in protected physical storage facilities, to which unauthorised persons do not have any access.

We retain electronic soft copies of personal data related to individual persons (employees, individual visitors of our corporate website, private clients and/or representatives or UBOs of corporate clients) in protected and encrypted IT facilities, free from unauthorised access.

All communication in which individuals share their personal data with IC REALTY LTD is secured and protected.

In line with the provisions and requirements of the Data Protection Regulation 679/2016/EU on the protection of personal data, you retain the following rights to your personal data:

• You have the right to review all personal information, which is related to you and which was / is collected during your visit of our corporate website and during the use and processing as described in this privacy policy at any time and to check the accuracy of personal data, which is related to you individually.
• You have the right to have done corrections, rectifications and updates to your personal data.
• You have the right to have your personal data deleted partly or completely.
• You have the right to obtain information on the use and purpose to process your personal data.
• You have the right to limit the purpose for processing and use of your personal data. However, this may have an effect on the accessibility of our regulated financial services rendered to you. You can refer to our DPO and/or our Compliance Department for further clarifications on this.
• You have the right to opt-out from commercial and non-commercial newsletters and notifications from IC REALTY LTD by notification to our DPO accordingly.
• You have the right to have all personal data, which is related to you and which is or had been collected during your visit and use of our corporate website and during your correspondence with IC REALTY LTD, being transferred to another Data Controller nominated by you.
• If your explicit consent was given with regards to the collection, use and processing of your personal data for a specific purpose that requires an explicit consent according to the Data Protection regulation 679/2016/EU, you have the right to withdraw your previously given explicit consent at any time by contacting our Data Protection Officer by electronic mail services to dpo@icaifm.com

You can submit your request to make use of the above rights to your personal data by contacting our Data Protection Officer (DPO) through electronic mail services to dpo@icaifm.com

The rendering of regulated financial services to our company’s prospective and/or existing clients requires the disclosure of personal data related to our prospective and/or existing clients in order to fulfil requirements defined by the regulatory legal framework in the Republic of Cyprus. Hence, we may pass on information related to our prospective and / or existing customers to third parties. These third parties are legally and economically independent from IC REALTY LTD and are located within the EU or in third countries. These third parties include, but are not limited to the following: external service providers, professional and legal advisors, administrators or subcontractors. IC REALTY LTD ensures the confidentially treatment of all disclosed data to external parties. You remain the rights to your personal data as described within this privacy policy. All third party agreements of IC REALTY LTD include a common standard on Data Protection.

Personal data, which is collected during the visit to our corporate website, may be disclosed to licensors of the software used on the Site. Please refer to our DPO in case you have questions on this or in case you want to make use of your rights related to your personal data as described in this privacy policy.

We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Site Terms and Conditions. Furthermore, your personal data is permitted to be disclosed to public bodies only in cases where the disclosure concerns matters of national and/or international security, the prevention or investigation of criminal activities, law enforcements, where a public interest is given, a juridical proceeding against the person, to which the personal data is related is pending or had been initiated or completed before and/or the personal security of the individual to which the personal data is related.

If you feel your personal data has been infringed by IC REALTY LTD, please get in touch with our DPO by electronic mail services to dpo@icaifm.com

Last updated 23rd May 2018