The retention of data is closely linked with the lawful basis under which the same is obtained and processed. More specifically, the Company being a regulated investment firm in Cyprus is obliged to retain its records for a period of at least 5 years. We may keep your data for longer if we cannot delete it for legal or regulatory reasons. Personal data retention period is based on the following main regulatory requirements:
- The Markets in Financial Instruments Directive (‘MiFID II’) and the corresponding Cyprus laws for the provision of investment services – five (5) years
- Investment Services and Activities and Regulated Markets Law of the Republic of Cyprus (L.87(1)/2017) - recording of telephone conversations or electronic communications relating to transactions concluded during the provision of client order services that relate to the reception, transmission and execution of client orders and those that are intended to result in transactions concluded in the provision of client order services, that relate to the reception, transmission and execution of client orders, even if those conversations or communications do not result in the conclusion of such transactions or in the provision of client order services shall be kept for a period of five (5) years and, where requested by the competent authority, for a period of up to seven (7) years.
- Applicable European and Cyprus legislation on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing – five (5) years after the termination of business relationship with the client or since carrying out of the last transaction;
- FATCA, CRS – collected information must be maintained by the Company for a period of six (6) years from the end of the period in which the territory of the client’s tax residence is identified.
- The retention of data is not limited in time in the case of pending legal proceedings or an investigation initiated by a public authority, provided that in each case the Company has been informed of the pending legal proceedings or the investigation initiated by a public authority within the retention period described hereinabove.