Privacy Policy
Last updated: 1 May 2025
1. Who We Are
P.Panagi & Sons Ltd (“we”, “us”, “our”) is a licensed customs clearing and forwarding agent registered in Cyprus. Our registered office is at the Cyprus Ports Authority Management Building, New Port, Limassol 3045, Cyprus.
We are the data controller for the personal data we collect through this website and in the course of providing our services. We are committed to protecting your privacy and handling your data in an open and transparent manner in accordance with the General Data Protection Regulation (GDPR) and the Processing of Personal Data (Protection of Individuals) Law of 2018 (Law 125(I)/2018) of Cyprus.
2. What Data We Collect
We collect and process the following categories of personal data:
2.1 Data You Provide Directly
- Contact form submissions: full name, email address, phone number, and the content of your message.
- Service enquiries: information about your shipment, goods, or customs requirements that you share with us by email, telephone, or in person.
- Client onboarding: passport or identity card details, VAT registration numbers, EORI numbers, company registration details, and other information required by Cyprus Customs for the purposes of customs clearance.
2.2 Data Collected Automatically
- Website analytics: anonymised usage data including pages visited, time on site, and browser type, collected via privacy-respecting analytics tools. We do not use Google Analytics or any tracking that identifies individual users.
- Server logs: IP addresses and access timestamps retained for security purposes for a maximum of 30 days.
3. How We Use Your Data
We use your personal data for the following purposes and on the following legal bases:
| Purpose | Legal Basis |
|---|---|
| Responding to your enquiries and providing quotations | Legitimate interests (Article 6(1)(f) GDPR) |
| Performing customs clearance and forwarding services | Performance of a contract (Article 6(1)(b) GDPR) |
| Complying with Cyprus Customs, VAT, and other legal obligations | Legal obligation (Article 6(1)(c) GDPR) |
| Sending service-related communications (e.g. shipment updates) | Performance of a contract (Article 6(1)(b) GDPR) |
| Improving our website and services | Legitimate interests (Article 6(1)(f) GDPR) |
We do not use your personal data for automated decision-making or profiling. We do not sell your data to third parties. We do not send marketing emails without your explicit consent.
4. How We Share Your Data
In the course of providing customs clearance services, we are legally required to share certain personal and commercial data with:
- Cyprus Customs (Tax Department of Cyprus): customs declarations, import/export entries, and supporting documents as required by EU and Cypriot customs law.
- Cyprus VAT Service: where applicable for VAT purposes.
- Shipping lines, freight forwarders, and port operators: to arrange the physical movement and release of your goods.
- Our IT service providers: who process data on our behalf under data processing agreements and are bound by confidentiality obligations.
All third parties we work with are required to handle your data securely and only for the purposes for which it was shared.
5. International Transfers
Your data is primarily processed within the European Economic Area (EEA). Where we use service providers outside the EEA (for example, cloud storage), we ensure appropriate safeguards are in place in accordance with Chapter V of the GDPR, such as Standard Contractual Clauses approved by the European Commission.
6. How Long We Keep Your Data
We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legal obligations:
- Customs and commercial records: a minimum of 4 years as required by Cyprus Customs legislation, and up to 7 years for VAT-related records.
- Contact form enquiries (no service provided): deleted after 12 months.
- Client records (service provided): retained for 7 years from the date of the last transaction.
- Server logs: deleted after 30 days.
7. Your Rights
Under the GDPR, you have the following rights regarding your personal data:
- Right of access: you may request a copy of the personal data we hold about you.
- Right to rectification: you may ask us to correct inaccurate or incomplete data.
- Right to erasure: you may ask us to delete your data where there is no legitimate reason for us to continue processing it, subject to our legal retention obligations.
- Right to restrict processing: you may ask us to limit how we use your data in certain circumstances.
- Right to data portability: you may request your data in a structured, machine-readable format.
- Right to object: you may object to processing based on legitimate interests.
- Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at [email protected] or in writing at our registered address. We will respond within 30 days.
You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection of Cyprus (Commissioner’s Office, 1 Iasonos Street, 1082 Nicosia, Cyprus; www.dataprotection.gov.cy).
8. Cookies
This website uses only strictly necessary cookies required for the website to function. We do not use advertising cookies, social media tracking cookies, or third-party analytics cookies that identify individual users. No cookie consent banner is required for strictly necessary cookies under the ePrivacy Directive.
9. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or damage. All data transmitted to and from this website is encrypted using TLS (HTTPS). Access to client data is restricted to authorised personnel only.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The “Last updated” date at the top of this page will be revised accordingly. We encourage you to review this page periodically.
11. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:
P.Panagi & Sons LtdCyprus Ports Authority Management Building
New Port, Limassol 3045, Cyprus
Email: [email protected]
Tel: +357 25 560175