BM Horizon Associates Limited (Cyprus) is a privately owned company. The Horizon Associates website provides information for European based residents which is non-regulated and for non-European residents which is regulated. For Non-EU business, Horizon Associates offer Investment Advice and Insurance Brokerage services to applicable jurisdictions via Financial Services Network Ltd, regulated by the Mauritius Financial Services Commission License No. C116016070. www.fsn-ltd.com. Horizon Associates partnership and data sharing agreement with Financial Services Network Ltd ensures any Non-EU personal data sharing is protected via third party data sharing agreements containing European Commission approved Standard Contractual Clauses.

Risk Warning: Any investment in financial instruments entails substantial risks, the degree of which depends on the nature of each investment, and may not be suitable for all investors. The value of any investment may increase or decrease in value and investors may lose all their invested capital.

This privacy policy will explain how our organisations use the personal data we collect from you when you use our website or become a Horizon Associates client. 

What data do we collect?

Horizon Associates shall collect and process personal information necessary to fulfil legal and regulatory requirements for the provision of Horizon Associates services and to improve our services to you. Horizon Associates gathers personally, identifiable information that may be used, either alone or in combination with other information, to personally identify, contact or locate you and may in certain circumstances, share information with third parties which will help Horizon Associates to construct a profile based on your requirements and preferences to provide our services effectively.

Such information shall include: 

• Information about you that you give us by filling our client forms/agreements, or by corresponding with us by phone, e-mail, in person or otherwise. It includes information you provide when you choose to use our services, participate in any company event and when you send any information to us under any capacity. The information you give us may include your name, address, e-mail address and phone number, financial information, personal description and photograph.

• Information we collect/receive from other sources about you if you use any of the services we provide and/or professionals we partner with. We are working closely with third parties including, for example, business partners, brokers, vendors, insurers, platforms, fund houses, trustees, search information providers, credit reference agencies. Such partnerships will be notified to you in the beginning or during the course of our relationship and the extent to which such partnerships are required to provide our services to you, such notification can be in the form of additional application forms of such partners or access to their website/platform and in such case shall be covered by GDPR in their own right as applicable.

In order for Horizon Associates to provide the most appropriate financial services and products to you Horizon Associates have data sharing agreements with the following companies, and your personal data may be shared securely with them:

API Global Ltd, SkyBound Wealth Management, Global Residential FZCO, IP Global Ltd, Cypeir Properties Ltd, Moennez Holdings Limited, CPZ Property Limited, Vistra Group, UK Legal Wills.

As a client you are responsible for the true and accurate nature of the personal information you provide to Horizon Associates. Your personal information and/or data shall be checked when it is collected and at regular intervals thereafter, if any personal information is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate. You are required to keep the company informed of any changes in personal information by emailing our Support Department at admin@horizon-associates.net.

Use of your Personal Data

Horizon Associates uses your personal information only as legitimate interest for the performance of our services to you, to improve our services, and enable us to inform you of any additional products, services or promotions relevant to you and in this respect. If you no longer wish to receive any promotional communication, you may opt-out of by contacting Horizon Associates via the Contact us page on the Company’s website or send an email to our Support Department at admin@horizon-associates.net.

Protection and Security of Personal Data

Horizon Associates does not sell, license or lease to anyone clients’ personal data, except as described in this Privacy. Horizon Associates has implemented appropriate measures to protect personal data from accidental loss, unauthorised or unlawful access or processing or destruction. Horizon Associates employs physical, electronic, and procedural safeguards to protect personal data and it does not store personal data for longer than is necessary for the provision of services or as permitted by the applicable regulations in accordance with Article 5 of GDPR – Principals relating to processing of personal data. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

The Personal Data we collect from you is stored locally at our servers and/or on cloud servers within the EU, Certain email communications and/or data transmitted to us over email and/or other means of electronic transfer of documents may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by third parties operating outside the EEA which work for us, where any personal data is transferred outside of the EEA Horizon Associates have data sharing agreements in place which contain the necessary Standard Contractual Clauses to ensure the security of your personal data. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and GDPR, especially in instances where data will be transferred to, and stored at, a destination outside the EEA.

Horizon Associates also informs you to maintain confidentiality and not share with others your usernames and private passwords (“credentials”) or as provided by Horizon Associates. You are responsible for keeping your credentials confidential. We ask you not to share your credentials with anyone.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data when you transmit this to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We have also implemented procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Disclosure of your Personal Data

You agree that we have the right to share your information with selected third parties we use to help deliver our products and/or services to you including:

• business partners, brokers, vendors, insurers, platforms, fund houses, trustees, search information providers or any other third party required for the performance of any contract we enter into with them or you;

• credit reference agencies and/or banking and financial institutions and/or auditors for, among others, the purpose of assessing your financial information (where this is a condition of us entering into a contract with you).

• Law enforcement agencies and regulatory bodies such as Mauritius Financial Services Commission and/or the Police for the purposes of complying with local and international regulations against money-laundering, fraud and the general prevention of crime and illegal activities.

• analytics and search engine providers that assist us in the improvement and optimisation of our site;

We will disclose your personal information to third parties:

• In the event that this is necessary for the delivery of our products and/or services to you (for example by using appropriate and compliant IT systems that transmit financial information and/or orders and/or execute payment and/or other financial transactions);

• If we are under a duty to disclose or share your personal data to comply with any legal and/or regulatory obligation, or to enforce or apply our terms of use and other agreements, or to protect the rights, property, or safety of us, our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, anti-money laundering and credit risk reduction;

• If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets. Should this happen you will be given the option to opt out of this data transfer;

We only allow the third parties we work with to process your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on our selected third parties to ensure they can only use your personal information to provide services to us and to you.

Your rights

Under Chapter 3 of the GDPR, you have the following rights, which we will always work to uphold:

1. Access – The right to be provided with a copy of your personal data, together with information regarding the processing of your data.

1. Rectification – The right to request rectification of any inaccurate or incomplete personal data we hold about you.

1. To be forgotten – The right to request erasure of your personal information based on legitimate grounds and where there is no good reason for us to continue to process or archive it.

1. Restriction of processing – The right to restrict the processing of your personal data, based on legitimate grounds or in the event that your contest the accuracy of the data, we no longer need to process or archive your data.

1. Data portability – The right to receive the personal data you provided to us, in a structured, commonly used and machine readable format and/or transmit that data to another controller, where technically feasible.

1. Objection – The right at any time to object to your personal information being processed for direct marketing (including profiling) or other automated individual decision-making.

1. Withdrawal of Consent – The right to withdraw consent at any time where consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof.

1. Complaint – The right to lodge a complaint regarding the processing of your personal data. Our details can be found in the General Information Section of this Policy. If you feel that your concerns have not been adequately addressed by us, you

1. have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Nicosia, Cyprus. (http:// www.dataprotection.gov.cy)

The right to access the information held about you, under certain conditions, may be subject to a fee of €25 to meet our costs in providing you with details of the information we hold about you. We shall aim to comply with requests for access to personal information as quickly as possible and will ensure that we comply with legislation unless exceptions apply. In such cases, the reason for any delay will be explained in writing to the data subject making the request. In processing a request, the identity of the data subject will need to be verified before information will be released. No personal data will be disclosed to a third party without the written consent of the data subject.

We reserve the right to refuse repeated/vexatious requests.

Further information about your rights can also be obtained from the Office of the Commissioner for Personal Data Protection in Nicosia, Cyprus.

Use of “Cookies”

Cookies are small pieces of information which use a unique identification tag and are stored on your computer, mobile device or any other device as a result of using the Horizon Associates website or other services the Company provides. Cookies are used to assess and improve the performance of our website and its products and services offered. Cookies are normally accepted automatically, however, you can refuse to have cookies stored on your device or if available, change the settings of your browser to refuse all cookies, and/or have your device notify you each time a cookie is sent to your device.

For more information about cookies, you may refer to the Company’s “Cookie Policy” available on our website.

Privacy policies of other websites

The Horizon Associates website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy. 

Changes to our privacy policy

Horizon Associates keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 21^st August 2023.

How to contact us

If you have any queries regarding this policy or the use of your personal data including making a request for access, please contact us via the Contact us page on the Company’s website or by email to our Support Department at info@horizon-associates.net or by telephone +357 25 312196 or by mail to our registered office BM HORIZON ASSOCIATES LIMITED 2 Markou Drako, Pano Kivides Limassol, 4715 Cyprus..

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Horizon Associates has not addressed your concern in a satisfactory manner, you may contact the Office of the Commissioner for Personal Data Protection at commissioner@dataprotection.gov.cy.