Privacy Policy

This Privacy Policy rules the Client’s use of products, services, technology, and content, offered by J.G. Meerkat Services Ltd (or “the Company”) through its website and any other feature that collectively constitute the Company services offering. It also governs without limitation the provision and use of the Client’s personal data and information in relation to the provided services.

As a Client, by entering into an agreement with the Company to use any of the services, you accept and consent to this Privacy Policy, and by doing so you consent to the use and disclosure of your personal information by the Company as provided for herein.

Definitions

“Controller” shall mean the Company;

“Personal Data” or “Information” shall mean any information relating to an identified or identifiable Client including legal persons such as Merchant entities and which will be provided in relation to receiving the Company services. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;

“Personal Data Filing System” or “Filing System” shall mean the Company system where the personal data of the Client is stored;

“Policy Update” shall mean any notice given to the Client in relation to policy changes prior to them taking effect;

“Processing of Personal Data” or “Processing” shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;

“Processor” shall mean a natural or legal person, public authority, agency or any other body which processes personal data on behalf of The Company;

“Recipient” shall mean a natural or legal person, public authority, agency or any other body to whom data are disclosed, whether a third party or not; however, authorities which may receive data in the framework of a particular inquiry shall not be regarded as recipients;

“Third Party” shall mean any natural or legal person, public authority, agency or any other body other than the Client, The Company, and the persons who, under the direct authority of The Company, are authorized to process the data;

“the Client’s Consent” shall mean any freely given specific and informed indication of his wishes by which the Client signifies his agreement to personal data relating to him being processed.

References to a specific gender and the use of “he”, “him”, “his” should also be construed as references to another gender for the purposes of this policy.

Overview

As the data controller registered with the Office of the Commissioner for Personal Data Protection, the Company will use the information provided strictly in accordance with the terms of this Privacy Policy.

The Company will not sell, lease, or otherwise distribute any of the Client’s information to third parties for marketing purposes unless the Client explicitly consents to such sale, lease or distribution. This does not preclude the Company from providing third parties such information that may be needed to enhance the Client experience or to simply offer certain services to the Client, and in such instances the Company will take every commercially reasonable precaution to safeguard the interests of the Client from any misuse of his personal data by the third party. Information to third parties will be provided under strict restrictions as those are described in this Privacy Policy.

The Privacy Policy may be amended from time to time at the Company’s sole discretion and as required by applicable laws and regulation. The amended version of the Privacy Policy will be posted on the Company website and will be deemed as received by all Clients. A notice for Policy updates will be given to all Clients either by posting such notice in an accessible area on the Company website and/or by sending an email notice to all Clients. The notice period will be 30 calendar days prior to the changes taking effect unless there are legal grounds that require otherwise. All future changes to this Privacy Policy will be incorporated by reference into this Privacy Policy and will take effect as specified. Do not engage any of the Company services if you disagree with this Privacy Policy, and if you are an existing Client and disagree with the amended terms of the Privacy Policy and wish to terminate your engagement you can do so by giving respective notice to the Company.

This Privacy Policy does not cover any third-party websites whose access and use are governed by their own privacy policies. The Company may provide links to such websites and the Client acknowledges that the provision of such links for access to such third-party websites, do not make the Company responsible for their operations and use of personal information practices. The Company strongly recommends to its Clients to carefully review the privacy policies of such third-party websites prior to submitting any personal information.

This Privacy Policy governs the use of the Company services and should not be construed as a standalone agreement. The Engagement Agreement with its terms and conditions and any Appendices and other relevant documents that the Client is required to abide by, collectively constitute “the Agreement”.

Collection of Information

The Company requires Clients to provide information following the engagement of its services and for providing the services the Client has contracted that include:

  1. Passport or National ID details;
  2. Daytime phone number and personal mobile phone number;
  3. Email;
  4. Background information including CVs and academic records;
  5. Certificates or other documentation that relate to bankruptcy or criminal records;
  6. Country of residence and residential address;
  7. Confirmation of personal wealth, sources of funds, operational information;
  8. Company financial statements including bank account confirmations and reconciliation records.

The Company may use a variety of information sources that do not violate any personal information privacy rules, in its legal entity assessment process.

The Company will also collect information that relates to the Client’s access of the Company’s website and includes but is not limited to visiting and leaving the website, the Company website page browsing history, the Client’s IP address of where the website was accessed, the time that was accessed and any other websites visited through links on the Company’s website. The Company may also use small data files such as cookies or similar technologies, and place them on the Client’s device to enhance and personalize the Client experience. Our Cookie Policy is that information collected through Cookies and similar technologies will solely be used by the Company for the purposes of better understanding its current and potential clientele and deliver the enhanced experience one should expect of it. Such information will not be shared with any third party. Persons who visit the Company’s website can manage their cookies and cookie preferences as well as other similar technologies through their browser’s or device’s settings. Blocking, disabling or deleting such cookies and similar technologies as your device and browser may allow you to, should not prevent you from accessing the information on the website.

All communication between the Client and the Company will be recorded and retained for reference purposes when and if required by the Company or the regulatory authority that supervises the Client operations.

All information procured during the provision of services, the device specific and location information collected during the accessing of the website, and any correspondence between the Client and the Company will constitute the “Information” that relate to the Client for the purposes of this Privacy Policy.

Information Use

Information collected from Clients are primarily used for the provision of the Company services in a manner that the Company deems fit. Information collected is stored and backed up at servers hosted in in the European Economic Area (EEA) in accordance with the European data protection laws, while it is being processed locally at the Company facilities (unless the jurisdictional laws provide otherwise).

The Client acknowledges and agrees that personal information provided for the Company service (in the beginning and during the relationship), can be used by the Company for the purposes of providing the services stipulated in the Engagement Agreement with the Client:

The Company communicates with its clients regularly through direct email communication and through general announcements/postings on its website. It also reaches Clients via telephone/skype or other similar telecommunication means for even more direct communication for a variety of reasons

The Company may also send other email notifications which are of a promotional or general information nature, such as news and third-party promotions, and are therefore not compulsory giving Clients the option to stop receiving them. The option to receive or stop such email communication can be managed by contacting one of the Company’s representatives and asking them to opt-out of such email service.

Information may also be provided to the Company auditors who may request such information during reconciliation exercises and for contacting clients to confirm the accuracy of the Company’s records.

Information Sharing

To offer the services, the Company deals with third party service providers (either to delegate important functions or to enhance the quality of the service. During these arrangements, the Company may disclose Client data to such third-party service providers so that they can provide the services they were engaged to provide.

The Company does not intent and will not share the personal information with third parties for marketing purposes for a fee (sale or lease). Should there be an exceptional case where such sharing of information may be considered, the Company may explore the option but not unless the Client provides explicit consent to do so. Any disclosures of such information will only be provided in line with the provisions of this Privacy Policy. Further, by accepting this Privacy Policy, the Client consents that the Company can and will do as if directed by the Client:

  1. Reveal to regulatory authorities, competent governmental authorities and agencies (other than tax authorities), law enforcement agencies, intergovernmental or supranational bodies, and other third parties with the requisite authority to request such information;
  2. Reveal information in response to criminal or civil legal process as requested by the competent courts of the relevant jurisdiction and as permitted under Cyprus Laws;
  3. Disclose information that is essential to auditors, commercial partners, operational partners, support services partners including public relations providers, and the Company affiliates for the complete provision of the Company services to the Clients;
  4. Provide information to the Client’s authorized representative;
  5. Provide information for statistical purposes that do not include personal identification information but are of rather aggregate nature.

Control of information

Should the Company be acquired by or merged with another entity in the future, the Client consents to the possession and use of this information by the successor entity and that the Privacy Policy will be binding upon the entity unless it is amended in which case it will be bound by the updated Privacy Policy.

The Company intends to maintain the data residency within the EEA and will try to ensure that any information or personal data that must be exported out of the EEA as a result of any above-mentioned reasons, will be appropriately protected. The Company will not export any personal data to third countries that do not enforce EU equivalent measures for the protection of personal data.

Security of Information

Security of Client information is of outmost importance to the Company, which has adopted commercially reasonable standards to ensure that the personal information is protected. The Company uses a range of safeguards to insulate information from unauthorized access.

Information Access

The information provided will be kept by the Company for a period of five years after a Client decides to terminate its Engagement Agreement with the Company. The Company will not use this information after termination in any way related to its services, but will only use it as necessary to assist with any law enforcement investigation, to honor any court sanctioned warrant, and for the prevention of any fraudulent action.

The Company responsibility

Clients who wish to know more about this Privacy Policy and receive information on how they can access their personal information as well as ask any specific questions in relation to this Privacy Policy, are encouraged to contact the Company, where one of our team members will be happy to address their inquiries.

The Privacy Policy was last updated on November 2017