1. Who is responsible for your data
A.T.N & Partners Ltd is the data controller for personal data described in this policy.
- Registered/business address: Navarino Business Centre, 18 Navarinou Street, Agios Andreas, CY-1100 Nicosia, Cyprus
- Postal address: P.O. Box 24300, CY-1703 Nicosia, Cyprus
- Email: info@atnpartners.com.cy
- Telephone: +357 22 400400
2. Scope of this policy
This policy applies when you browse atnpartners.com.cy, submit an enquiry, request a consultation, subscribe to our newsletter, apply for a role, or otherwise communicate with us through the website. Separate engagement terms or privacy notices may apply if you become a client, employee, supplier or business contact.
3. Personal data we collect
Depending on how you use the website, we may collect the following categories of information:
- Contact and enquiry details, including your name, email address, telephone number, company or organisation, service of interest and the content of your message.
- Recruitment information, including your CV, employment and education history, qualifications, contact details and any supporting documents you choose to provide.
- Newsletter information, consisting of your email address and subscription source.
- Technical and usage information collected after consent, including pages viewed, external referrer domain and a randomly generated pseudonymous visitor identifier stored in your browser.
- Advertising-attribution information collected after consent, including landing page, referrer, campaign parameters (UTM values) and Google click identifiers such as gclid, gbraid or wbraid.
- An approximate two-letter country code when you open the contact page. This is obtained through a country-lookup service using the IP address visible to that service; we do not receive your precise location from it.
- Communications and records of our correspondence with you.
4. How we collect personal data
- Directly from you when you complete a form, upload a CV, subscribe, email or call us.
- Automatically from your browser or device, but only for non-essential analytics and advertising measurement after you accept cookies.
- From service providers that help us operate the website, deliver communications, protect the service and measure advertising performance.
- From publicly available or professional sources where this is lawful and relevant to a business enquiry or recruitment process.
5. Why we use your data and our legal bases
- To respond to enquiries, arrange consultations and take steps you request before entering into a professional engagement. Our legal basis is taking pre-contractual steps and our legitimate interest in managing business enquiries.
- To assess applications and communicate about employment opportunities. Our legal basis is taking pre-contractual steps, complying with employment-law obligations and our legitimate interest in recruitment.
- To send newsletters and professional updates where you have subscribed. Our legal basis is consent; you may unsubscribe at any time.
- To operate, secure, troubleshoot and improve the website. Our legal basis is our legitimate interest in maintaining a safe and effective website.
- To measure website use and advertising performance. Our legal basis is your consent, which you may refuse or withdraw without affecting access to the website.
- To establish, exercise or defend legal claims and meet legal, regulatory, professional or tax obligations. Our legal basis is compliance with law and our legitimate interests.
7. International transfers
Some technology providers may process data outside Cyprus or the European Economic Area. Where GDPR requires it, we use an adequacy decision, approved contractual safeguards or another lawful transfer mechanism, together with supplementary measures where appropriate.
8. How long we keep personal data
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including applicable legal, regulatory, professional, accounting and reporting requirements. Enquiry and recruitment records are periodically reviewed and deleted or anonymised when no longer needed. Newsletter details are retained until you unsubscribe or we discontinue the service. Consent-based campaign attribution stored in your browser is configured for a maximum use period of 90 days.
9. Security
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure. No internet service can be guaranteed completely secure, so please avoid including unnecessary sensitive information in website forms.
10. Your data-protection rights
Subject to the conditions and exceptions in applicable law, you may ask us to:
- Provide access to your personal data and information about its use.
- Correct inaccurate or incomplete personal data.
- Delete personal data or restrict how it is used.
- Provide eligible data in a portable format.
- Object to processing based on legitimate interests or to direct marketing.
- Withdraw consent at any time, without affecting processing carried out before withdrawal.
- Review a decision if any decision with legal or similarly significant effects were made solely by automated means. We do not currently use the website for such decisions.
11. Requests and complaints
To exercise a right or ask a privacy question, contact info@atnpartners.com.cy. We may need to verify your identity before acting on a request. You also have the right to complain to the Office of the Commissioner for Personal Data Protection in Cyprus or, where applicable, another competent supervisory authority.
12. Changes to this policy
We may update this policy to reflect legal, operational or technology changes. The revised version will be posted on this page and identified by a new “Last updated” date. We will provide an additional notice where a material change requires it.