This page contains the Policy adopted by Freemont Group (‘’Freemont Group’’, “the Company”, “we” “us”, “our) as to how we serve the Articles 12 to 14 of the General Data Protection Regulation (GDPR – EU 679/2016 “on the protection of natural persons with regard to the processing of personal data and on the free movement of such data”) and the National Law 125/I/2018 (Data Protection Framework) for transparency and the provision of Information to the interested Parties, with regards to the processing of Personal Data. This Policy explains what information we collect from you or you provide to us, how we use it and with whom we share that information, as well as all required information referred to in the Data Protection Framework.
Contents
1. Definitions
Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as (indicatively) a name, an identification number, age, address, occupation, contact details, education, work, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. The Controller
Regarding personal data in the cases where we determine the purposes and the means of processing, the Controller is the legal person Freemont Group, address Freemont Services DMCC Dubai Branch, Bayswater Tower, Level 18, Office 10, Al Abraj South Street, Business Bay, Dubai, United Arab Emirates , telephone: +971 444 57 900, e-mail info@freemontgroup.com.
3. Principles we comply with
In Freemont Group the personal data are:
processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of ‘lawfulness, fairness and transparency’);
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (principle of ‘purpose limitation’);
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (principle of ‘data minimisation’);
accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (principle of ‘accuracy’);
kept in a form which permits identification of data subjects for no longer than it is necessary or as required by relevant Laws (principle of ‘storage limitation’);
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures (principle of ‘integrity and confidentiality’).
Finally, we are able to demonstrate compliance with the aforementioned principles (principle of ‘accountability’).
4. When we collect Personal Data
We, as the Controller, collect Personal Data from you in the following cases:
When you contact us directly or through our corporate partners, or through our website or social media accounts, or when emailing to us in order to be informed or to request information about the services we offer, or when you visit our premises.
If you agree to receive our services or when you are involved in events related to the provision of our services.
When you fill in any of our communication or other forms in paper or electronic format.
When you cooperate with us, or if personal data of yours are legally disclosed to us by third parties or partners under contracts or agreements.
During an evaluation process aiming to improve our services.
When you contact us in any way as an employment candidate sending your CV.
When we discuss potential cooperation with you.
When you are employed by us.
In addition, we process personal data, which third parties, usually legal entities, disclose to us in the case we are a Processor on their behalf.
We process your personal data for the purposes set out in detail below.
5. Minors’ Personal Data
We collect minors’ personal information only under verifiable parental consent and only when required by the legal framework, in cases where we are able to control it. For example, it is not possible to check information that is disclosed to us without physical presence (e.g., online). In any case, if we become aware having collected any minor’s personal information without verifiable parental consent, we will directly erase such information (according Article 8 of the GDPR).
6. Personal data we collect and process
Data from the following categories of personal information about you, may be collected and processed by us as the Controller, per case in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Privacy Policy:
Contact information such as full name, address, country of residence, nationality, telephone /fax number and email address of yours or another individual you may indicate on your behalf.
Occupational status information (occupation, position, company, activities).
Information required for signing a contract such as your contact details and the ones of people involved in the information contained in the contract, the terms of the agreement and the services, requirements, amounts, signatures, terms of payment in accordance with the legal framework.
Information related to evaluating your personal and economic profile of you and your dependents (due diligence and know your client), source of income and wealth declaration, utility bill for the proof of address as required by the legal framework, curriculum vitae.
Politically Exposed Persons’ Questionnaire and FATCA Questionnaire where applicable.
Payment details (IBAN or account number, tax identification number, desired payment method, payment terms, depositor’s details).
Client’s history (satisfaction rate, quotes received, market data, transaction data, complaints, product problems, terms of cooperation) and evaluation ratings.
Apps / websites / social media data, like IP address, location cookies, dates and time of connection, language selection, name under which you appear in the media, photo, any information that is public and comments or information included in any email attachments.
Any information referred in your CV or any additional documents you send us, when you are interested in working with us.
Information provided by you in the course of our potential cooperation.
Your image captured grom the legally operating CCTV when you visit our offices.
It is noted that in cases where we act as the Processor on behalf of our Client-Legal entity, we may require additional information and documents; in such case the Controller is obliged to inform you.
Our employees are internally informed through policies and procedures and internal documents on the collection and processing of their personal data.
7. Purpose of the processing and legal basis
The processing of personal data from us as the Controller, is based on one of the “legal bases” as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data). The legal bases on which the collection and processing of personal data is based (in most of the cases) are:
your consent (Article 6.1.a) or explicit consent (Article 9.2.a);
processing that is necessary for the performance of a contract to which you as the data subject is party, or in order to take steps at your request as the data subject prior to entering into a contract (Article 6.1.b);
the compliance with our legal and statutory obligations (Article 6.1.c);
the safeguarding of our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of yours as the data subject (Article 6.1.f).
The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:
Consent: when you contact us physically or electronically either as interested in our services or as a potential corporate partner, when contacting us as candidates for employment, or when informing you during our promotional activities, or when you visit our website and social media accounts, or when you ask connection to our Wi-Fi, or when you give us your personal/ professional card.
Explicit Consent: when you agree to upload your photograph in our website or social media accounts.
Performance of a contract: for the assessment of the capacity to become a client of ours and according the legal framework, when you are our client for serving you and for the fulfilment of our agreement, when you are one of our suppliers or collaborators for the compliance with the contractual terms of our agreement, or when we communicate with you prior to, or under the contract, as well as for settlement of the liabilities of the two parties.
Legal Obligations: for the compliance with our legal obligations towards the legal framework and especially the money laundry and the sanctions framework, obligations towards authorities such as prosecuting authorities, police, labour law and regulatory authorities, tax and auditing authorities or judicial authorities.
Legitimate interests: to improve our services, or when investigating and managing any potential incident, to receive our payment, or for the assessment of persons and situations. In this specific legal basis is also based the video surveillance system (CCTV) in our premises that we legally operate for the protection of people and the property.
Our employees are internally informed through documents and procedures on the purpose and legal bases when collecting and processing their personal data.
8. Retention of personal data
We store personal data we process as the Controller for as long as required by the respective processing purpose and any other lawful linked purpose.
Personal data that are collected under the legal basis of ‘Performance of a contract’ or the legal basis of ‘Legal Obligations’ (Article 6.1.b and 6.1.c of the GDPR), are retained after the expiry of the contractual and legal obligations as long as the relevant institutional framework permits.
Data that may be necessary for our legitimate interests as the Controller (Article 6.1.f) shall be kept until the reason for storing such data ceases. The recording of the video surveillance system is kept no longer than 18 days and then it is permanently deleted through overwrite.
Personal data included in an offer that does not lead to a cooperation agreement are kept for 36 months.
Employment candidates’ personal data are kept for 12 months unless you prior withdraw your consent.
Specifically for personal data we process based on your consent, such data are kept from obtaining your consent and until it is revoked or their retention is no longer necessary.
Personal data that are no longer necessary are securely destroyed or anonymised.
9. Security of your personal data
We have implemented reasonable and appropriate organisational and technical measures to protect the personal data and the entire information we process, and in particular any specific categories of personal data. We follow international standards and practices to ensure the security of the information we process in relation to the associated risks of processing. We ensure that your personal data is processed legally and securely the possible extent, by adhering to policies and developing and implementing procedures.
For example, the following security measures have been implemented to protect personal data against unauthorised use or any other form of unauthorised processing:
Access to personal data is restricted to a limited number of authorised employees under a need-to-know basis and specific contracts.
Our employees are bound to confidentiality rules and agreements, with limited classified access to the necessary data only.
We ensure that our employees are provided with the appropriate training in order to handle personal data promptly and in accordance with the legal framework.
We select trusted collaborators who are committed in writing, in accordance with Article 28 of the Regulation, to the same obligations regarding the protection of personal data. We reserve the right to audit them in accordance with Article 28 (3) (h).
The necessary data transfer is done by secure procedures.
In our ICT systems used for the processing of personal data, adequate and proportional technical measures are received to prevent loss, unauthorised access or other forms of illegal processing. In addition, access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet or a web site cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.
It is obvious that part of the security measures is not subject to public disclosure.
10. Disclosure of your Personal Data
We receive organisational measures to ensure that the recipients of personal data are kept to a minimum. The personal data we collect is disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully process as the Controller, may be accessed (or disclosed) on a case-by-case basis by:
Any supervisory or persecutory authority within its role.
Any public or judicial authority where required by law or judicial decision.
Supervising Authorities in our sector of activities.
Company’s auditor and legal advisor and only for the required amount of personal data to fulfil their role under a duty of confidentiality.
Our data protection officer under specific agreement.
The Insurance cooperating company and only for the relevant part of the information.
Partner banks (of the company, the staff or affiliates and suppliers), only for payment related data.
The Compliance System external auditor only for the necessary and audit relevant pieces of information and data.
We do not transfer personal data to 3rd countries or international organisations unless you explicitly request such transfer.
11. Territorial Scope
The personal data we collect is processed within the European Economic Area (EEA) and/or an adequacy decision area according Article 45 of the GDPR.
12. Your rights as a data subject and exercising such rights
You have the right to be informed, the right of consent when this is the legal basis of data collection and processing, the right of access to your personal data, the rights of rectification and erasure (in cases it is permitted), the right to restriction of processing, the right to data portability, the right to object. If processing is based on your consent, you may withdraw it at any time.
The right to be informed is exercised through this privacy and personal data protection notification. In some cases, it is also mentioned on documents – forms we are using.
We inform you that we are not using software of decision making solely based on automated processing. We implement profiling only in relation to clients and according the legal framework.
The right of consent is provided by design as we have reviewed all processing activities and ask your consent when this is required.
Right of access: you have the right to obtain from us confirmation as to whether or not your personal data are being processed as well as other relevant information, and, where that is the case, access to your personal data.
Right of rectification: you have the right of rectification of your inaccurate personal data as well as to have incomplete personal data completed by providing a supplementary statement.
Note: Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by informing us of any changes to your personal information we do process.
Right to erasure (‘right to be forgotten’): we have to answer such right when:
your personal data are no longer necessary in relation to the purposes for which we collected it
withdraw your consent on which the processing is based and where there is no other legal basis for the processing
your personal data have been unlawfully processed
personal data have to be erased for compliance with a legal obligation we are subject to
personal data have been collected in relation to the offer of information society services.
We reserve the right to refuse this right if the processing is necessary for compliance with any legal obligation, we are subject to, or for reasons of public interest, or for the foundation and exercise or support of our legal claims (according Article 17 § 3).
Right to restriction of processing: you have the right to restriction of processing when:
you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead
we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims
you objected to processing pending the verification whether our legitimate grounds override those of yours.
Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and under an explicit request such data to be transferred to both you and another natural or legal person who will process it when:
the processing is based on consent, or when the data were processed for the performance of a contract to which you were a party; and
the processing is carried out by automated means.
Right to object: you have the right to object to the processing of your data at any time when the reason for the processing relates to direct marketing.
In the event that you make such request in a written or electronic form regarding any of the above rights, will assess your request and respond within one month of its receipt, either for its satisfaction or to provide you with objective reasons preventing it from being satisfied, or, given the complexity of the request and the number of requests at the given time, request an extension of response for a further two months period (Article 12.3).
The initial exercise of your rights is free of charge. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to answer or charge you an administrative fee.
Please note that we are not allowed to respond requests when we are the Processor. In this case you should contact the Controller.
If you have any concerns about our use of your personal, you have the right to make a complaint to the Data Protection Commissioner’s Office, which regulates and supervises the use of personal data in Cyprus. Before such complaint, you may contact us if you wise, so we can provide you with complete information and support.
13. In Case of a Data Breach
In the event of a breach of the security and integrity of the personal data processed, we will take the following measures (in accordance with Article 33 and 34 of the Regulation) and we will:
assess it in order to implement the appropriate procedures needed to limit the breach
examine the extent of the breach and the sensitivity of the data included
evaluate the risk and its impact on your rights and freedoms
endeavour to reduce as much as possible the damage that is or may be caused
notify within a time limit of 72 hours of becoming aware of the breach, the National Personal Data Protection Authority, if required
assess the impact on your privacy and take appropriate measures to prevent the repeating of the incident
In the event we are the processor, we will inform the Controller as soon as possible.
14. Links with other sites
Our Site might contain links to other websites. Freemont Group has no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services and is not responsible for the privacy policies of third-party websites to which links are provided. You should check the privacy policies on these sites before providing any personal information.
15. Communication with the National Authority
If you wish to contact with the Supervisory Authority, the contact details are: 15 Kypranoros str., Nicosia 1061, Cyprus, telephone +357.22818456, e-mail: commissioner@dataprotection.gov.cy.
16. Contacting with us
If you have any concerns or questions about this Privacy Policy or any personal information we collect about you, please do not hesitate to contact our Data Protection Officer, at dpo@freemontgroup.com.
17. Update of the present Policy
This policy firstly published on 25th May 2018 was updated at September 30, 2025 and will be reviewed when there is a significant change. This review will be available on the same website.