Privacy Policy

Hamilton Berkley Ltd is an Administrative Service Provider regulated by the Cyprus Bar Association. This policy explains how we handle personal data on www.hamiltonberkley.com and across our services. It applies alongside our Cookie Policy and Terms & Conditions.

1. Introduction

Hamilton Berkley Ltd (the “Company”, “we”, “us”, “our”) is committed to protecting the privacy and personal data of all individuals interacting with our website and services.

This Privacy Policy explains how we collect, use, process, store, and protect personal data in accordance with:

• The EU General Data Protection Regulation (EU) 2016/679 (GDPR)
• The Cyprus Law 125(I)/2018 providing for the protection of natural persons with regard to the processing of personal data
• The Prevention and Suppression of Money Laundering and Terrorist Financing Law (L.188(I)/2007)
• Applicable Cyprus Bar Association (CYBAR) directives and obligations

2. Data Controller

The data controller is:

3. Personal Data We Collect

We may collect and process the following categories of personal data:

3.1 Information You Provide

• Full name
• Contact details (email, phone number, address)
• Identification data (passport, ID, etc.)
• Financial and corporate information
• Information submitted via contact forms or correspondence

3.2 Automatically Collected Data

• IP address
• Browser type and device information
• Website usage data (via cookies and analytics tools)

3.3 Data Required for Compliance

In order to comply with AML/CFT regulations, we may collect:

• Identity verification documents
• Source of wealth and source of funds information
• Corporate structure and beneficial ownership information

4. Purpose of Processing

We process personal data for the following purposes:

• Provision of administrative, corporate, fiduciary and advisory services
• Client onboarding and due diligence (KYC/CDD/EDD)
• Compliance with AML/CFT and regulatory obligations
• Communication with clients and prospective clients
• Website administration and security
• Improvement of services and user experience
• Legal and regulatory reporting

5. Legal Basis for Processing

We process personal data based on:

• Performance of a contract
• Compliance with legal obligations (including AML/CFT requirements)
• Legitimate interests (e.g., business operations, security)
• Consent, where required

6. AML and Regulatory Obligations

As a regulated Administrative Service Provider:

• We are legally required to collect, verify, and retain personal data.
• We may conduct ongoing monitoring of client relationships.
• We may report suspicious activity to competent authorities (e.g., MOKAS).

Such processing is mandatory and cannot be restricted by the data subject where required by law.

7. Data Sharing and Disclosure

We may share personal data with:

• Regulatory and supervisory authorities (e.g., Cyprus Bar Association, MOKAS)
• Banks and financial institutions
• Legal, accounting, and professional advisors
• Service providers and IT systems (processors)
• Affiliates or group entities (if applicable)

Data may also be disclosed where required by law or court order.

8. International Data Transfers

Where necessary, personal data may be transferred outside the European Economic Area (EEA), subject to:

• Adequacy decisions by the European Commission; or
• Appropriate safeguards (e.g., Standard Contractual Clauses).

9. Data Retention

Personal data is retained:

• For the duration of the client relationship; and
• For at least 5 years after termination, in accordance with AML legislation; or
• Longer where required by law or regulatory authorities.

10. Data Security

We implement appropriate technical and organisational measures to ensure:

• Protection against unauthorised access
• Confidentiality and integrity of data
• Secure storage and processing

11. Your Rights

Under GDPR, you have the following rights:

• Right of access
• Right to rectification
• Right to erasure (subject to legal limitations)
• Right to restriction of processing
• Right to data portability
• Right to object

Please note: certain rights may be limited where processing is required for AML/CFT compliance.

12. Cookies

Our website uses cookies to:

• Enhance user experience
• Analyse website traffic
• Improve functionality

You may manage cookie preferences via your browser settings. For full details, see our Cookie Policy.

13. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices.

14. Updates to this Policy

We reserve the right to amend this Privacy Policy at any time. Updates will be published on our website.

15. Contact

For any queries regarding this Privacy Policy or your personal data, please contact:

Email: ft@hamiltonberkley.com

16. Supervisory Authority

You have the right to lodge a complaint with: