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Privacy Policy

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Effective Date: 25 June 2026
Last Updated: 25 June 2025

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This Privacy and GDPR Policy outlines how Calmco Ltd, a company incorporated under the laws of the Republic of Cyprus with registered office at [insert address], processes and protects personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the Law 125(I)/2018 of Cyprus.

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1. Scope and Purpose

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Calmco Ltd is committed to protecting the privacy and personal data of its clients, partners, employees, and other individuals with whom it interacts. This policy applies to all personal data collected and processed by Calmco Ltd in connection with its fiduciary, trust management, corporate services, and other professional activities.

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2. Data Controller

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Calmco Ltd acts as the Data Controller for the personal data it collects and processes. For inquiries regarding this policy or your personal data, you may contact:

Data Protection Officer (DPO)
Calmco Ltd
info@calmco.co.cy
Phone: 22-272-160

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3. Types of Personal Data Collected

 

We may collect and process the following categories of personal data:

  • Identification data: name, date of birth, passport or ID number

  • Contact details: address, email, phone number

  • Financial data: bank account information, tax residency, investment profiles

  • Professional data: occupation, employer, titles

  • Compliance data: KYC documentation, source of wealth/funds, legal documents

  • Digital information: IP addresses, cookies (via website)
     

4. Legal Basis for Processing

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We process personal data based on one or more of the following legal grounds:

  • Performance of a contract

  • Compliance with legal obligations (e.g., AML/CFT, tax reporting)

  • Legitimate interests (e.g., risk management, business development)

  • Consent (where required)
     

5. Purpose of Processing

 

  • Personal data is processed for the following purposes:

  • Establishing and managing trusts and corporate structures

  • Compliance with anti-money laundering and regulatory requirements

  • Communicating with clients and service providers

  • Performing fiduciary, administrative, and legal functions

  • Recordkeeping and risk assessment

  • Marketing (subject to consent)
     

6. Data Sharing and Disclosure


We may share personal data with:

  • Public authorities (e.g., Registrar of Companies, Tax Department, MOKAS)

  • Financial institutions, auditors, and legal advisors

  • Trusted third-party service providers under strict confidentiality agreements

  • Other entities in the Calmco group (if applicable), within the EEA

 

We do not sell or rent personal data.
 

7. International Transfers


If data must be transferred outside the European Economic Area (EEA), we ensure such transfers comply with GDPR safeguards, including Standard Contractual Clauses or adequacy decisions.
 

8. Data Retention

 

Personal data is retained for as long as necessary to fulfil the purposes for which it was collected and to comply with legal and regulatory obligations. Typically, this is 5 to 10 years after the end of the business relationship.

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9. Your Rights

 

Under GDPR, you have the following rights:

  • Right to access your personal data

  • Right to rectification of inaccurate data

  • Right to erasure ("right to be forgotten")

  • Right to restrict processing

  • Right to data portability

  • Right to object to processing

  • Right to withdraw consent at any time

  • Right to lodge a complaint with the Office of the Commissioner for Personal Data Protection(www.dataprotection.gov.cy)
     

10. Data Security

 

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These include secure servers, access controls, data encryption, and staff confidentiality obligations.
 

11. Cookies and Website Use

 

Our website uses cookies to improve user experience and analyse traffic. By using our site, you consent to the use of cookies in accordance with our Cookie Policy. You may disable cookies via your browser settings.
 

12. Updates to This Policy

 

This policy may be updated periodically to reflect legal or operational changes. The latest version will always be available on our website. We encourage you to review it regularly.

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For further information, please contact our Data Protection Officer at info@calmco.com].

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