Privacy policy

ECREDO LIMITED (hereinafter “eCREDO’’) welcomes you to our website (hereinafter the “Site”). eCREDO, is a growing and evolving European Company which provides business advisory services to its client as described below.

eCREDO is a strategic partner and collaborator with Contomobile UAB, a company registered in the Republic of Lithuania, with registration number 304285884, having its registered offices at Tuskulenu str. 33c-55, LT-09219 Vilnius, Lithuania, an electronic money institution, licensed and supervised by the Bank of Lithuania (EMI Licence No: 0005), (hereinafter the ‘’Contomobile’’).

Therefore, in this privacy policy (“Privacy Policy”), the expressions “we” and “us” means eCREDO.

This Privacy Statement describes how we collect, use, process and disclose certain personal information.

This Privacy Policy describes the data processing activities conducted by eCREDO and it does not extend to the processing of personal data by any collaborators, affiliates, or third-party entities, even if such processing occurs in relation to the eCREDO’s services. eCREDO is not responsible for the content, practices, or policies of third parties, including collaborators and/or partners, even if they are accessed through the Company’s services.

eCREDO LIMITED, is a limited liability company duly incorporated and validly existing under the Laws of the Republic of Cyprus with registration number HE394761 and having its registered office at Vasili Michailidi 21-23, 3026 Limassol, Cyprus (hereinafter ‘’eCREDO’’). It was incorporated in 2019, having as main activities the aspects of the financial industry.

eCREDO, amongst others, undertakes to liaise with Contomobile and coordinate the onboarding procedure of the Client with Contomobile regarding data collection, to liaise with Contomobile for any issues occurring during the use of the services provided by Contomobile as well as to provide routine account maintenance and support activity as me be required.

The Company respects your privacy and is committed to protecting your personal data through its compliance applicable privacy and the General Data Protection Regulation 679/2018 (hereinafter the “GDPR”). Therefore, we advise you to carefully read the above privacy policy for your information and please do not hesitate to contact us for any further clarification you might have.

• Directly from you and/or
• Through third parties and/or
• Through this website.

• information you provide to the company by filling in the forms we initially requested from you;
• information you provide to the company when you submit a consent or when you report a problem through the Website;
• information provided by you (including email addresses) in case you contact us;
• information received by third parties authorised by you.

We will collect personal information about you which you provide to us when using the Site, for example, when you contact us through the Site, when you request information or otherwise provide personal information to us. Such information may include (but is not limited to) the following information and/or Data:

• your full name
• contact details such as address, telephone number and email address
• date of birth
• proof of identity documents
• proof of address documents
• financial information
• information required to provide to you with our services as described to our Service Agreement, as such terms may be amended and/or supplemented from time to time between the parties to it.
• correspondence information received from you and/or third parties as described to the Service Agreement which has been signed between us and you (“the Service Agreement”), as such terms may be amended and/or supplemented from time to time between the parties to it.

Please note that you must ensure that the personal information you provide to us is accurate and complete.

We collect, use, store and process personal information about you for the following purposes:

• to provide you with our Services – in accordance to the Service Agreement as such Services may be amended and/or supplemented from time to time between the parties to it and/ or to respond to any request from you through our correspondence;
• for customer management purposes – to provide you with the customer support including any notice, for example changes about any service we offer;
• to enable you to access and use the Site;
• advertising – to provide you with information regarding products and services that you might be interested (see the “Marketing” section below);
• to comply with our legal obligations – for example for Anti-Money Laundering and Fraud prevention checks and in order to comply with AML Regulations;
• where requested by law enforcement for investigation of crime. 

The collection, disclosure, process and transfer of personal data must meet the below circumstances, which are used in order to establish our legal basis:

• it is necessary in order for us to perform a contract between the individual and the Company;
• it is necessary in order for us to take measures to enter into a contract with the individual where it has requested us to do so;
• it is necessary for us to establish, exercise or defend legal claims;
• it is necessary for us to be compliant with our legal obligations or
• if none of the conditions listed above apply, the individual has explicitly consented to the processing.

We follow a data retention policy, depending on the activity for which the data have been collected. The retention policy determines the retention time of each data and when to destroy information that is no longer needed for legal, regulatory or commercial reasons. For example, eCREDO is obliged by the Tax Authorities to keep the data up to 6 years after the ceasing of the business relationship.

Overall, the criteria used to establish the period for which personal data will be stored is determined by regulatory or legal requirements. This is also supported by our Data Protection Policy that such information must not be kept for any longer than necessary to fulfil the purposes for which it has been collected.

We will not disclose personal information obtained from you to any third parties unless this is required in accordance to our Service Agreement for the provision of our Services to you. However, we may share Personal Information with our affiliates for the purpose of responding to your requests or otherwise as necessary for the purposes described above:

• in connection with legal proceedings or potential legal proceedings;
• where is required to do so by law or any other Governmental or law enforcement agency (including but not limited to our issuing banks, and our third-party partners.)
• if you breach our Service Agreement.

1. Affiliate companies – service providers
2. Third parties such as authorities, agents and administrative personnel in various countries (Tax Authorities, Bank Institutions etc.)
3. Legal Successors– we might disclose personal information to a buyer or a successor in the event of merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets

Unless you have specifically consented to the transfer, we will only transfer personal data outside the European Economic Area (EEA) as described to the paragraph below.

We may store, process and/or transfer the personal information you submit to us through use of the Site to countries outside of the European Economic Area including (without limitation) to the USA. Personal data transferred outside of the EEA will be stored and processed by affiliate companies or services provides, or representative offices for business and management purposes, to perform a contractual obligation owed by us to you and/or to provide you with information or services that you have requested.

We will not transfer any of your Personal Data outside the EEA unless the transferor ensures that:

• we transfer the data to a country or international organisation which the EU Commission has decided to ensure an adequate level of protection for your personal data;
• the transfer of your personal data is subject to adequate safeguards, which may include binding corporate rules or Standard Data Protection Clauses adopted by the EU Commission; or
• one of the derogations in the GDPR to transfer personal data outside the EEA applies.

eCREDO has implemented appropriate security measures to ensure the protection of Personal Information from any unauthorized access or disclosure.  Moreover, we consider your privacy and the safeguard of your personal data by default and by design. This means that we implement those technical and organizational measures that only your personal data that are necessary for the purposes detailed in this privacy policy will be processed. We restrict access only to the personnel or third party who require to access your data to deliver our service at optimum levels. In addition, our employees had been trained on how to use, handle and process personal data, according to the provisions of the GDPR. Finally, we continuously balance the risks for your rights and freedoms posed by any processing through our established risk management framework and control environment.

We and/or our partners will only use the personal information obtained from you to enable us to provide you with the customer support including any notice, for example changes about any product and/ or service we offer, advertising – in case you have provided us with your consent – we may communicate with you in order to inform you about services and/or products offered by us or other third parties for which you might be interested.

You will be receiving advertising material from eCREDO, only if you have provided your explicit consent. In case you feel that you need to revoke this consent, you will be provided with an automated way to opt-out (unsubscribe) from all marketing e-mails sent by eCREDO. Please follow the instructions from the e-mail you received to do so. In the unlikely case you receive unwanted e-mail from our Company, please forward a copy of that e-mail to the Data Protection Officer of eCREDO at: [email protected].

You, as Individual, have the following rights:

1. Right of access – request access to any personal data we hold about you;
2. Right of rectification -have any personal data which we hold about you which is inaccurate or incomplete rectified.
3. Right to be forgotten – have personal data erased.
4. Right to restriction of processing – have the processing of your personal data restricted.
5. Right of portability – To be provided with the personal data that you have supplied to us in a portable format that can be transmitted to another organization without hindrance.
6. Right to object – object to certain types of processing, including processing based on legitimate interests, automated processing (which includes profiling) and processing for direct marketing purposes; and

7. Right to object to automated processing, including profiling -not be subject to a decision that is based solely on automated processing which produces a legal effect, or which has a similar significant effect for the individual.

If you wish to exercise any of the rights set out above, you must make the request in writing to the Data Protection Officer, for whom all the details are described above.  Please note some of these rights are restricted in some circumstances.

If you have provided your consent to any of the processing of your personal data, you have the right to withdraw your consent to that processing at any time, where relevant. You must contact the Data Protection Officer if you wish to do so.

If you object to processing based on legitimate interests, we must no longer process that personal data, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or that the processing is required for the establishment, exercise or defense of legal claims.

If you wish to access or update the Personal Information you submitted to us, or to make any inquiries about the processing of your information, please contact us. We provide individuals with access to their Personal Information as required by applicable data protection and privacy laws.

This website contains links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. This privacy policy applies solely to information collected by this Site.

Our Company has its own social media (Facebook, Instagram, LinkedIn, You tube etc.) We remind you that these platforms are publicly accessible and any content, comment, personal information you provide will be visible to the general public and for this reason we recommend that you be careful with the content of the information you put using these platforms. Information about the processing of personal data by the relevant social media can be found in their privacy terms.

Cookies are small files on your computer, which can store information that you transmit when accessing the internet. They are transmitted via the web browser to the computer’s hard drive. Cookies cannot transmit any information from a computer system. They instead help to make a return visit to the Site as simple and user friendly as possible. Some cookies remain on the computer’s hard drive so your computer gets recognized on your next visit. You can change your browser options at any time to deactivate cookies. (Some functions are only accessible when cookies are enabled and we therefore recommend allowing cookies.)
Click this link to read our cookie policy.

eCREDO has assigned ARETI CHARIDEMOU & ASSOCIATES L.L.C as the personal Protection Agent:

Areti Charidemou & Associates LLC – Law Firm

21 Vasili Michailidi Street | 3026 Limassol – Cyprus

Postal Address: PO Box 54708 | CY-3727 | Cyprus

D: +357 25 50 82 19| T: +357 25 50 80 00 | F: +357 25 50 80 90

E: [email protected]

eCREDO reserves the right to change this Privacy Policy from time to time. Please check the Privacy Policy frequently and particularly before you submit additional personal information via the Website. All revisions of this Privacy Policy will be posted on the web site via a link from the homepage. We also display the effective date of the Privacy Statement on the top of this page. 

It is very important the principles of privacy to be followed and we should take all the appropriate measures to avoid any breach or loss of these data.

We ensure that the personal data you disclosed to us, are saved in a platform which is protected with additional security factors.

Any breach of the GDPR and/or other relevant Data Protection Acts will be taken seriously and if you consider that the data protection principles have not been followed in respect of personal data about yourself or others you have the right to lodge a complaint with the relevant data protection supervisory authority.

Our Protection Supervisory Authority is the Personal Data Protection Bureau (Independent Supervisory Authority for the Protection of Individuals). If you have any issues with our processing of your personal data and would like to make a complaint, you may contact the Personal Data Protection Bureau on (+357) 22 818 456 or at 1 Iasonos, 1082 Nicosia, Cyprus.

If you require this Privacy Policy to be provided to you in paper form and/ or you need any further clarification, please contact our Data Protection Officer, at [email protected] or via phone on (+357) 25 508 219.