Privacy Policy

1. Who is responsible for your information

ALFRED is the brand used for our private client services. The legal entity acting as data controller must be identified below.

• Legal company name: [To confirm]
• Registered address in Cyprus: [To confirm]
• Privacy contact email: [To confirm — professional business email to be supplied]
• Company registration details and any data protection officer contact: [To confirm, where applicable]

2. Information provided in enquiries

The enquiry form asks for your name, email address, optional telephone number, area of interest, a description of your requirements and permission to use your details to respond. Please do not include sensitive financial information, identification documents or confidential third-party information in an initial enquiry.

Enquiry email delivery is not yet active. A submission does not send an email or establish a client relationship. Form information is validated to check its format and is not saved in persistent browser storage by the enquiry form. This does not mean that hosting infrastructure keeps no technical records.

To confirm: the complete information collected when email delivery and client management become operational, including any third-party or client-onboarding data.

3. Purposes and lawful bases

The intended purposes are responding to enquiries, discussing an engagement, coordinating services within an agreed scope and meeting applicable legal obligations.

To confirm: the lawful basis for each activity under the GDPR. Depending on the activity, this may include steps taken at your request before entering a contract, performance of a contract, legal obligations, legitimate interests or consent where appropriate. The form’s permission checkbox is not a substitute for identifying the correct lawful basis for each purpose. Where processing relies on consent, it may be withdrawn without affecting the lawfulness of earlier processing.

4. Sharing and international transfers

Private client coordination may require sharing relevant information with professional advisers, suppliers or specialists within the agreed scope. The final notice must explain who receives information, for what purpose and whether each recipient acts as a processor or an independent controller.

To confirm: hosting, email and other service providers; recipient categories; data-processing arrangements; processing locations; and any transfers outside the EEA, including the applicable transfer safeguards. No referral partners are named in this draft.

5. Retention and security

The final policy must set out how long enquiry, client and technical information is retained, or the criteria used to determine those periods, together with applicable legal requirements.

Data retention arrangements: [To confirm — enquiry periods, client records, statutory records, backups and deletion procedures].

The enquiry form uses input validation and basic spam checks. These measures are not a guarantee of absolute security. To confirm: operational access controls, hosting records, email safeguards and other technical and organisational measures.

6. Cookies, technical information and external fonts

The website loads fonts from Google Fonts, which involves your browser requesting resources from Google. Such requests can transmit technical information such as an IP address and browser details.

To confirm: the live website’s cookies, hosting and diagnostic records, any analytics or other third-party tools, their purposes and retention, and whether a separate cookie notice or consent controls are required. This draft does not assert that the website is cookie-free or that no analytics are used.

7. Your data protection rights

Subject to the conditions and exceptions in applicable law, you may request access to your personal information, correction, erasure, restriction of processing or data portability, and may object to certain processing. Where consent is the lawful basis, you may withdraw it.

Requests should be directed to the privacy contact above once confirmed. Identity verification may be necessary to protect your information. You may also lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus or another competent supervisory authority.

To confirm: the privacy contact and procedures for handling requests. Any automated decision-making or profiling must also be reviewed and disclosed where applicable.

8. Review and updates

Effective date: [To confirm after approval]. This draft requires review by the business and an appropriately qualified adviser before adoption. It must be updated when enquiry delivery, providers or processing practices change.