Our Privacy Policy – ensuring your confidentiality at all times

At Bronger Peters Limited, we place the utmost importance on confidentiality and discretion – a cornerstones of how we work and embedded in Our Values.

Bronger Peters Limited (“we”, “us,” “our”) is incorporated in the Republic of Cyprus and, together with our affiliates, is the data controller for the personal information described below. We comply with the EU General Data Protection Regulation (GDPR) 2016/679 and all applicable local data‑protection laws.

1. Sources of Personal Data

We obtain your personal information through:

Direct interactions (forms you complete, information you send us by email, phone, fax or via our website);
Third parties (your employer, agents, advisors, custodians or other intermediaries);
Public records and databases (e.g., when conducting background, anti‑money‑laundering or due‑diligence checks);
Networking events and conferences where you share business cards or other contact details.

2. Types of Data Collected

We may collect any of the following categories of data, where relevant to our engagement with you:

Identity & Contact: Name, address, email, telephone, job title.
Verification: Date of birth, passport or national‑ID details, tax identification number, nationality, domicile.
Financial Profile: Income, assets, liabilities, bank‑account and payment details, source‑of‑wealth information.
Professional & Personal: Employment history, education, family circumstances, objectives and risk profile.
Compliance Information: Politically exposed‑person (PEP) status, anti‑money‑laundering screening results, FATCA/CRS data.
Technical: IP address, device and browser information, log‑in timestamps, time zone.

3. Purposes and Legal Bases for Processing

Purpose	Legal Basis	Recipients
On‑boarding, service delivery and proposals	Performance of contract (Art. 6(1)(b))	Internal teams; service‑delivery partners; professional advisers (e.g. lawyers, accountants)
Regulatory compliance (KYC, AML, tax)	Legal obligation (Art. 6(1)(c))	Regulators; law‑enforcement agencies; auditors
Business management, record‑keeping, analysis	Legitimate interests (Art. 6(1)(f))	Internal management; group entities; advisors
Marketing of relevant services and events	Legitimate interests (Art. 6(1)(f))	In‑house marketing team; email‑service providers
Consent‑based activities (if you opt‑in)	Consent (Art. 6(1)(a))	As specified when consent given

4. Disclosure and International Transfers

Where necessary to deliver our services or comply with legal obligations, we may share data with:

Affiliates within our group;
Your appointed agents, custodians or advisors;
Third‑party service providers bound by contractual confidentiality obligations;
Courts, regulators, tax authorities or law‑enforcement agencies as required by law.

Transfers outside the EU occur only if:

The destination country has an EU‑approved adequacy decision;
The recipient has signed the EU’s Standard Contractual Clauses;
The data subject has given explicit consent; or
A valid EU‑US data‑transfer framework registration applies.

5. Data Retention

We retain personal data only as long as necessary for the purposes collected, and in line with:

AML/KYC rules: 5–7 years after the end of our relationship;
Other contractual or legal requirements: generally up to 7 years post‑engagement.

6. Your Rights

Under the GDPR, you may:

Request access to or a copy of your personal data;
Ask us to rectify inaccurate information;
Object to or restrict processing;
Withdraw consent (for consent‑based processing) without affecting prior processing;
Request erasure (“right to be forgotten”);
Receive data you provided in a structured, machine‑readable format (“data portability”);
Lodge a complaint with a supervisory authority.

To exercise any right, please contact our Data Protection Officer at dpo@brongerpeters.com.

7. Marketing Preferences

We may send you newsletters, event invitations and legal or market updates that we believe are relevant. You can opt‑out at any time by emailing dpo@brongerpeters.com or clicking “unsubscribe” in any marketing message.

8. Security Measures

We employ robust technical and organizational safeguards (encryption, access controls, secure backups and physical security) to prevent unauthorized access, loss, alteration or disclosure of your data. Our staff and service providers are contractually obliged to maintain confidentiality.

9. Tracking & Analytics

To enhance our site and services, we may use:

Web analytics (e.g. Google Analytics with IP anonymization) to understand usage patterns;
Cookie‑based tools for session management and performance monitoring;
Consent‑management platforms to record and manage your cookie preferences.

10. Contact Information

Data Protection Officer
Email: dpo@brongerpeters.com

For any complaints you may have for Cyprus you may contact the Data Commissioner of the Republic of Cyprus at:

http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_en/home_en?opendocument