Ι. ABOUT US
Wade Adams (Middle East) Limited and its group Companies are leading project development and construction Companies in Middle East and Cyprus.
The Group is currently headquartered in Dubai, UAE, the centralized Administration including Data Processing is performed.
ΙΙ. PROCESSING AND CONTROLLING OF YOUR PERSONAL DATA
In order to keep carrying out our business and/or to fulfill our obligations towards the projects that we undertook to carry out, it is necessary to collect certain personal data that are of course protected and processed according to Data Protection laws and regulations. In this respect our Company becomes the Data Controller.
As the Data Controllers we have responsibility towards our Data Subjects (our clients and/or affiliates) to give access to the personal data that we possess either to inform, to amend and/or update or to even delete certain of the personal information that is being held.
This is because every client and/or affiliate who is a Data Subject, has the right to know what personal data we collect and what they are. Hence, every Data Subject has the ability to request that we correct any inaccurate data, or to delete them (always under certain conditions).
This Policy is posted below on our website www.wadeadams.com and will apply regardless of whether or not you access it by any means or device.
For any queries, please contact our firm’s Data Protection Officer (DPO) Mr. Petros Georgallis at DPO@WADEADAMS.COM
|Customer application for cooperation||Essential personal information, identification data, communication information, statement of consent, curriculum vitae if necessary|
|Communication with clients and information for services||Communication information|
|Communication with clients and the sending of financial information||Personal Identification|
|Storage of data in the central storage||Personal Identification and information concerning the case|
|Submission of essays to regulatory authorities/ law imposing authorities||Personal information, identification data, communication information, contracts, documents, account statements|
|Deletion of information||Personal information held|
We will not reveal and/or disclose your personal information/data to any third party which in a way is different to what the Policy states . However, we retain the right to disclose your personal information/ data with third parties according to the below:
3.1 Considering that we are obliged to comply with the law and regulations, it may be necessary to disclose your information, to apply our term and conditions or to protect the rights of a third party or of our property, safety and customers.
3.2 In order to cooperate with the law imposing authorities as well as the investigation and prosecution of illegal activities, for example frauds. We retain the right to disclose any of your personal information to relevant authorities which according to our own judgment is necessary or it is related to any fraud investigations or other illegal activities. These authorities include:
● Data protection officer
● Organizations combatting money laundering (AML) / Organizations combatting terrorism (CTF) or any other relevant authorities
3.3We retain the right to disclose in certain occasions some of your personal information to third party service providers with whom we share a contractual relationship or to subcontracting technicians who assist us with the smooth running of our internet platform and/or website . Additionally, we may disclose some of your personal information to third party supporting/managing services with whom we also share a contractual relationship, however we strive to ensure that these third parties with whom which we share some of your information will not use your data for any other reason other than to fulfill our agreed services. In case of a third party breaching their duty not to share your information, then all necessary legal actions will be taken and the wrongdoer shall be penalized accordingly. To achieve everything mentioned, the following third parties may acquire your data:
● Payment services
● Organizations combatting money laundering, combatting terrorism and fraud
● Platform Providers
● Service Providers
3.4 We will not divulge your personal information to third parties outside the countries where there is no data protection legislation. However, if it is absolutely necessary to share your data with such a country then we will take all possible measures to protect your data according the Regulations and legislation imposed as per the relevant country laws. Additionally, we will update the current Regulations in order to better cover cross-border information transactions and to better protect your privacy.
4.1 It’s our policy to keep the information of our clients only for the necessary time period for which the task requires according to the data minimalization and storage limitation principles. For the following reasons your information will be stored for at least seven (7) years after you cease to be our clients. In addition, we align the retention of your data with possible variations arising from the exercise of your privacy rights. However, in some cases, specific personal information may be retained beyond this time period due to possible legal obligations and/or legal interests. Such cases are issues which are may be related to:
● Money Laundering
● Financial Outstanding
● Legal Obligations
● Any other legal issues
5.1 At any time, while we retain or process your personal data, you retain the following rights and may submit a request using your personal account:
● Right of access – you have the right of access to the personal data we retain about you
● Right of correction – you have the right to correct inaccurate or incomplete data we retain about you. (for further information check paragraph 6 below)
● Right of deletion – you can request that the data we retain about you to be deleted from our files and we are obliged to satisfy your request only in specific cases
● Right to restrict processing – you have the right to request that the processing of your personal data be restricted, and we are obliged to comply with this request when certain conditions apply
● Right to data portability – you have the right to request that the data we retain about you to be transferred to any other third-party organization (indicate in written form)
● Right of objection – you have the right to object the processing of personal data concerning you, under certain conditions
5.2 Your requests mentioned in paragraph 5.1 will be evaluated and an answer about their progress will be issued as soon as possible, definitely one month from their submission.
If your request is rejected, we will communicate the reasons for the rejection. Additionally, you have the right to file a complaint directly with the regulator and the Data Protection Officer of our company (DPO@WADEADAMS.COM) .
5.3 We reserve the right to reject requests that are unreasonably repetitive, require disproportionate technical efforts or have disproportionate technical consequences, endanger the privacy of others or are impossible to implement.
6.1 Excluding exceptional cases, every client can check, update, or delete certain personal information.
6.2 In addition, every client can request a copy of their personal information to be delivered to their personal email or any other way they wish. For your protection, you will need to prove your identity to receive such copies. You should include the necessary information to identify yourself and additional relevant information that will help us fulfill your request. If you wish to terminate our partnership or provide you with our services, you can contact the company’s management. We are obliged to comply with such requests unless we have a legal obligation or a legal interest in not deleting the data.
7.1 The protection of your data is extremely important to us and in this regard, we constantly strive to provide all possible means of security for the protection of your personal data, the restriction of unauthorized access and / or possible changes. These measures include information security measures in line with current best practices for protecting your privacy. These tools include technical and procedural actions and monitoring and tracing actions, aimed at securing data from misuse, unauthorized access or disclosure, loss, alteration, or destruction.
8.1 We strive to continually review and update current Policies in order to comply with legal and regulatory requirements, while providing optimal protection of each client’s personal data. Any updates are notified to all our clients through our website, via mail or email.
9.1 If at any time you believe that we do not comply with the provisions related to the current Policy or any other matter related to data protection, you may contact us through email at DPO@WADEADAMS.COM. We inform you that our Data Protection Officer is Mr. Petros Georgallis.
10.1 It has to be ensured that all legal files with confidential information either in hard copy or digital form have to be secured in the workspace at the end of the day in locked cabinets or in computers with encryptions and/or protected with passwords.
10.2 Computers Any electronic device such as Computers, laptops, mobile devices have to be locked when the workspace is not occupied.
10.3 Computers and laptops should be shut down at the end of the workday and not put in sleep mode.
10.4 Files with confidential information should be locked in a drawer or a cabinet when no one is around the office or at the end of the workday.
10.5 The cabinets with the records should remain closed and locked when they are not in use or when no one is around to supervise them.
10.6 The keys which secure the office drawers containing files with confidential information should not be left in an office without supervision, they should always be at a secure place.
10.7 Laptops should either be locked with a cable or be stored in a drawer with a lock or other secure place. Laptops should be securely stored when kept unattended.
10.8 Passwords should not be shared with others or noted on stickers placed on the computers or left where others have access.
10.9 Printed confidential documents should be immediately moved away from the printer.
10.10 Documents should be destroyed using special devices to cut the paper in pieces always complying with safety procedures.
10.11 Laptops, tablets and other portable electronical devices should be retained at a minimal number in the office.
10.12 Storage devices such as CDROM, DVD and USB should be secured using encryption and stored in safe places.