Borg Athanasiou Holdings is committed to maintaining the privacy, confidentiality and security of individuals, organisations and business partners who interact with our websites, services, communications and related business activities.

This Privacy Policy explains how Borg Athanasiou Holdings and its associated entities may collect, use, disclose, retain and protect information obtained through our websites, digital platforms, professional communications and other interactions with individuals and organisations.

We recognise that privacy is an important component of professional and commercial relationships. We therefore seek to handle information responsibly, transparently and in a manner consistent with the nature of our business and the relationships we maintain with clients, partners, suppliers, professional advisers, prospective business partners and other stakeholders.

By accessing or using our website or voluntarily providing information to us, you acknowledge the practices described in this Privacy Policy.
 

1. About This Privacy Policy

This Privacy Policy applies to information collected through websites, digital platforms, online enquiry forms, electronic communications and other digital channels operated by Borg Athanasiou Holdings.

Borg Athanasiou Holdings is a holding and investment organisation whose activities may include the ownership, oversight, development and strategic management of businesses operating across different sectors and jurisdictions.

Individual companies within the Borg Athanasiou Holdings group may operate independently and may maintain their own privacy policies, terms of use or data-handling practices where appropriate.

Where you interact directly with a particular company within the group, the privacy practices applicable to that company may differ from those described in this Policy.
 

2. Information We May Collect

The information collected by Borg Athanasiou Holdings depends on the nature of your interaction with us.

Information may be provided voluntarily when you:

• submit an enquiry through our website;

• contact us by email or other communication channels;

• request information about our businesses or services;

• submit a consultation or partnership enquiry;

• communicate with representatives of Borg Athanasiou Holdings;

• express an interest in a business opportunity;

• participate in a professional or commercial discussion;

• communicate with us regarding a potential investment, partnership or transaction;

• apply for an employment or professional opportunity where such functionality is available;

• correspond with us regarding an existing business relationship; or

• otherwise provide information to us voluntarily.

Depending on the circumstances, information may include:

• full name;

• professional title or position;

• company or organisation name;

• email address;

• telephone number;

• business address;

• country or jurisdiction;

• professional background;

• information relating to an enquiry or business opportunity;

• information contained within correspondence;

• information voluntarily provided in documents or attachments; and

• other information reasonably necessary to respond to or manage the relevant interaction.

We seek to limit the collection of information to information that is reasonably relevant and necessary for legitimate business, professional, administrative or relationship-management purposes.
 

3. Information Collected Automatically

When you access our website, certain technical information may be collected automatically through standard website technologies.

This information may include:

• IP address;

• browser type and version;

• device type;

• operating system;

• approximate geographic location derived from technical information;

• pages visited;

• time spent on particular pages;

• referring website or source;

• date and time of access;

• website interaction data; and

• other technical information generated through normal website operation.

This information is generally used for purposes such as maintaining website security, monitoring website performance, identifying technical problems, understanding general usage patterns and improving the functionality and presentation of our digital platforms.

Where possible, technical information is considered in aggregate rather than as information intended to identify individual users.
 

4. How We Use Information

Information collected by Borg Athanasiou Holdings may be used for legitimate business and operational purposes, including:

• responding to enquiries and correspondence;

• communicating with individuals and organisations;

• facilitating professional and commercial discussions;

• managing business relationships;

• considering strategic partnerships and opportunities;

• discussing consultancy, investment or commercial opportunities;

• managing relationships with clients, suppliers and professional advisers;

• maintaining appropriate internal business records;

• administering our websites and digital platforms;

• improving website functionality and user experience;

• monitoring website performance;

• maintaining website and information security;

• preventing misuse, fraud or unauthorised activity;

• complying with applicable legal or regulatory obligations;

• protecting the rights, property and interests of Borg Athanasiou Holdings and its associated entities; and

• undertaking other activities reasonably necessary for the operation and management of our business.

Information will not ordinarily be used for purposes materially unrelated to the reason for which it was provided without an appropriate basis for doing so.
 

5. Professional and Commercial Communications

Borg Athanasiou Holdings operates in an environment where communications may involve commercially sensitive information, strategic discussions and confidential business matters.

Information voluntarily provided during professional correspondence may therefore be retained and used to properly understand, manage and respond to the relevant relationship or opportunity.

Individuals and organisations should exercise appropriate discretion when transmitting sensitive commercial, financial, legal or confidential information through general internet communication channels.

Where a formal confidentiality agreement, non-disclosure agreement or other contractual arrangement applies to a particular relationship, the handling of information may additionally be governed by the terms of that agreement.
 

6. Confidentiality

Borg Athanasiou Holdings places significant importance on discretion and confidentiality in its professional relationships.

Reasonable administrative, technical and organisational measures are taken to protect information from unauthorised access, disclosure, alteration, misuse or loss.

Access to information may be limited to individuals, advisers, service providers or representatives who reasonably require access for legitimate business purposes.

However, no method of transmitting or storing information electronically can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect information, we cannot guarantee the absolute security of information transmitted through the internet.

Users should consider the sensitivity of information before submitting confidential or commercially sensitive material through an unsecured communication channel.
 

7. Disclosure of Information

Borg Athanasiou Holdings does not sell, rent or commercially distribute personal information to unrelated third parties.

Information may, however, be disclosed where reasonably necessary for legitimate business, operational, professional or legal purposes.

This may include disclosure to:

• companies within the Borg Athanasiou Holdings group;

• professional advisers;

• legal advisers;

• accountants and auditors;

• technology and website service providers;

• hosting and infrastructure providers;

• communication and enquiry-management platforms;

• analytics providers;

• professional consultants;

• financial institutions where reasonably required;

• government authorities or regulatory bodies where legally required; and

• other service providers or parties where disclosure is reasonably necessary to facilitate a legitimate business activity.

Where third parties are engaged to provide services to Borg Athanasiou Holdings, we seek to ensure that access to information is limited to what is reasonably necessary for the relevant service.

Information may also be disclosed where required or permitted by applicable law, regulation, court order or other lawful authority.
 

8. Group Companies and Associated Entities

Borg Athanasiou Holdings may own, control, manage or have interests in a number of companies and business ventures operating in different industries and jurisdictions.

Where appropriate, information may be shared between entities within the group for legitimate purposes, including:

• group-level administration;

• strategic management;

• business development;

• relationship management;

• professional communication;

• financial and operational administration;

• compliance and risk management; and

• the coordination of group activities.

Individual group companies may have separate websites, systems and privacy policies. Where information is submitted directly to one of those entities, that entity may be responsible for handling the information in accordance with its own applicable policies.
 

9. International Information Handling

Borg Athanasiou Holdings may operate, maintain relationships with organisations, or utilise service providers in multiple countries and jurisdictions.

As a result, information may be accessed, stored or processed in a jurisdiction other than the jurisdiction in which it was originally provided.

Where information is transferred internationally, we seek to take reasonable steps to ensure that the information continues to receive appropriate protection and is handled in accordance with applicable requirements.

The privacy and data-protection laws applicable in another jurisdiction may differ from those in the jurisdiction where information was initially collected.
 

10. Third-Party Services

Our websites and digital platforms may rely on third-party providers for services including:

• website hosting;

• website development and maintenance;

• cloud storage;

• enquiry and contact management;

• email communication;

• analytics;

• security;

• website performance monitoring;

• payment processing where applicable; and

• other technical infrastructure.

These third parties may process limited information as necessary to provide their services.

Borg Athanasiou Holdings does not control the independent privacy practices of external service providers. Users are encouraged to review the privacy policies of third-party services where they interact directly with those services.
 

11. External Websites and Links

Our website may contain links to websites operated by third parties, including portfolio companies, business partners, professional organisations or other external entities.

A link to an external website does not necessarily indicate an endorsement, affiliation or responsibility for that website or its privacy practices.

Once you leave a Borg Athanasiou Holdings website, the collection, use and protection of information may be governed by the privacy policy of the external website.

We encourage users to review the privacy policies of external websites before submitting personal or confidential information.
 

12. Cookies and Similar Technologies

Our website may use cookies and similar technologies to support website functionality and understand how visitors interact with our digital platforms.

Cookies may be used for purposes including:

• enabling essential website functionality;

• remembering preferences;

• improving website performance;

• understanding general website usage;

• measuring traffic and engagement;

• identifying technical issues; and

• improving the user experience.

Some cookies may be provided by third-party services integrated into the website.

Users may be able to control or restrict cookies through their browser settings. Disabling certain cookies may affect the functionality or presentation of parts of the website.
 

13. Website Analytics

We may use analytics and performance-monitoring technologies to understand how visitors use our website.

Analytics information may help us understand:

• which pages receive the most engagement;

• how visitors navigate the website;

• general traffic patterns;

• website performance;

• technical issues; and

• areas where the website experience may be improved.

Analytics information is primarily used for operational and website-improvement purposes.
 

14. Data Retention

Borg Athanasiou Holdings retains information only for as long as reasonably necessary for the purposes for which it was collected or where retention is otherwise necessary for legitimate business, administrative, legal or regulatory purposes.

The appropriate retention period may depend on:

• the nature of the information;

• the purpose for which it was collected;

• the nature of the relationship;

• ongoing business requirements;

• legal or regulatory obligations;

• potential disputes or claims; and

• legitimate record-keeping requirements.

Where information is no longer reasonably required, we may take reasonable steps to delete, destroy or anonymise it, subject to applicable retention obligations.
 

15. Data Security

Borg Athanasiou Holdings takes reasonable precautions to protect information against:

• unauthorised access;

• accidental loss;

• misuse;

• unauthorised disclosure;

• alteration;

• destruction; and

• other inappropriate handling.

Security measures may include access controls, authentication procedures, secure technology infrastructure, administrative controls and other measures appropriate to the nature of the information.

Despite these measures, no electronic system, network or method of transmission can be guaranteed to be completely secure.

If you believe that information provided to us has been compromised or that an unauthorised disclosure may have occurred, we encourage you to contact us promptly.
 

16. Accuracy of Information

We seek to maintain information that is reasonably accurate and appropriate for the purposes for which it is used.

Where you provide information to us, you are encouraged to ensure that the information is accurate, complete and current.

If you become aware that information we hold about you is inaccurate or outdated, you may contact us to request that the information be reviewed or corrected where appropriate.
 

17. Access and Privacy Requests

Depending on the applicable laws and circumstances, individuals may have rights relating to information held about them.

These may include rights to:

• request access to personal information;

• request correction of inaccurate information;

• request deletion of information where appropriate;

• withdraw consent where processing is based on consent;

• raise concerns regarding the handling of information; or

• request further information regarding our privacy practices.

Requests should be made using the contact details provided on our website.

Borg Athanasiou Holdings may need to verify the identity of the person making a request before providing access to information or making changes.

Certain information may not be capable of being disclosed, corrected or deleted where retention or disclosure is required or permitted by law or where another legitimate exception applies.
 

18. Children and Minors

Our website and services are primarily intended for professional, commercial and general business audiences.

We do not knowingly seek to collect personal information from children for purposes unrelated to the legitimate operation of our website or business.

If a parent, guardian or other responsible person believes that a child has provided personal information to us unnecessarily, they may contact us so that the matter can be reviewed.
 

19. Marketing and Communications

Where appropriate, Borg Athanasiou Holdings may communicate with individuals and organisations regarding business developments, services, opportunities, events or other matters relevant to an existing professional relationship.

We do not intend to use information obtained through ordinary website enquiries for unrelated promotional purposes without an appropriate basis for doing so.

Where applicable, individuals may request that certain forms of non-essential communication cease.
 

20. Business Transactions

In the course of operating and developing its business, Borg Athanasiou Holdings may participate in transactions including acquisitions, disposals, restructures, investments, mergers, joint ventures or other corporate activities.

Where such activities occur, information may be transferred or disclosed as reasonably necessary in connection with the relevant transaction, subject to applicable confidentiality, privacy and legal requirements.

Any successor entity or relevant organisation receiving information may become responsible for its handling in accordance with applicable law and relevant arrangements.
 

21. Legal and Regulatory Requirements

Borg Athanasiou Holdings may collect, use or disclose information where reasonably necessary to:

• comply with applicable laws and regulations;

• respond to lawful requests from authorities;

• comply with court orders or legal processes;

• establish, exercise or defend legal rights;

• investigate suspected unlawful activity;

• protect the security of our systems;

• prevent fraud or misuse; or

• protect the rights, property, safety and legitimate interests of Borg Athanasiou Holdings, its associated entities and other parties.
   

22. Changes to This Privacy Policy

Borg Athanasiou Holdings may periodically review and update this Privacy Policy to reflect changes in:

• our business operations;

• website functionality;

• technology;

• third-party services;

• legal or regulatory requirements; or

• our privacy and information-management practices.

Any updated version of this Privacy Policy will be published through the relevant website or digital platform.

The revised Policy will take effect from the date of publication unless otherwise stated.

We encourage users to review this Policy periodically to remain informed about how information may be handled.
 

23. Acceptance and Use of the Website

By accessing or using the Borg Athanasiou Holdings website, you acknowledge that you have read and understood this Privacy Policy.

Where information is voluntarily submitted through our website or communication channels, you acknowledge that the information may be collected, used and handled in accordance with this Policy and applicable law.

Nothing in this Privacy Policy is intended to create contractual rights beyond those required by applicable law.
 

24. Contact

If you have questions regarding this Privacy Policy, wish to raise a privacy concern, or would like to make a request regarding information held by Borg Athanasiou Holdings, you may contact us through the contact details provided on our website.

We encourage privacy enquiries to include sufficient information for us to understand the nature of the request and respond appropriately.

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