ANTIPAROS ADVISORY LIMITED
PRIVACY POLICY
Effective date: 31 July 2026
Last updated: 31 July 2026
1. Introduction
1.1 Antiparos Advisory Limited (“we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what personal data we collect through our website at www.antiparosadvisory.com (the “Site”), how we use it, who we share it with, and what rights you have.
1.2 This Privacy Policy covers personal data we collect through the Site and through your correspondence with us. It does not cover personal data we process in the course of providing consultancy services to clients under an engagement — that processing is addressed in the relevant engagement letter or data processing agreement.
1.3 Please read this Privacy Policy together with our Cookie Notice and our Terms of Use.
2. Data controller and contact details
2.1 The controller of your personal data is:
Antiparos Advisory Limited UIC: 208287675, Registered office: Ul. Vera Mutachieva 3-4, Sofia 1407, Republic of Bulgaria, Email: elle@antiparosadvisory.com
2.2 If you have any question about this Privacy Policy or wish to exercise any of your rights, please contact us by email at elle@antiparosadvisory.com, marking your message “Data protection enquiry”.
2.3 We have not appointed a data protection officer, as we are not required to do so under Article 37 of the GDPR.
3. What personal data we collect
We collect the following categories of personal data:
3.1 Data you give us directly
3.2 Data collected automatically
3.3 We do not knowingly collect any special category personal data (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning sex life or sexual orientation) or any criminal offence data through the Site. Please do not send us such data through the Site.
3.4 The Site is not directed at children and we do not knowingly collect personal data relating to children through it.
3.5 You are not obliged to provide any personal data to us. However, if you do not provide your contact details we will not be able to respond to an enquiry or add you to our mailing list.
4. Why we use your personal data, and our legal basis
We only use your personal data where the law allows us to. The table below sets out the purposes for which we use your personal data and the legal basis under Article 6 of the GDPR on which we rely.
4.2 Where we rely on legitimate interests, we have carried out a balancing assessment and consider that our interests do not override your rights and freedoms. You may ask us for further information about that assessment, and you have the right to object (see clause 9).
4.3 We do not carry out any automated decision-making or profiling that produces legal effects concerning you or otherwise significantly affects you.
4.4 We will not use your personal data for a new purpose that is incompatible with the purposes above without informing you and, where required, obtaining your consent.
5. Marketing
5.1 We will send you marketing communications by email only where you have subscribed to our mailing list, or where you have enquired about or purchased our services and have not opted out (a “soft opt-in” under applicable electronic communications rules).
5.2 Every marketing email we send contains an unsubscribe link. You may also unsubscribe at any time by emailing elle@antiparosadvisory.com. We will action your request without undue delay and in any event within a reasonable time.
5.3 If you unsubscribe, we will retain a minimal record of your email address on a suppression list so that we do not contact you again. We rely on our legitimate interests and legal obligations for this.
5.4 Withdrawing consent to marketing does not affect the lawfulness of processing carried out before withdrawal, and does not prevent us from contacting you for non-marketing purposes, for example to respond to an enquiry you have made.
6. Who we share your personal data with
6.1 We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.
6.2 We share personal data with the following categories of recipient:
6.3 Where we use processors, we have in place written contracts required by Article 28 of the GDPR which require them to process personal data only on our instructions, to keep it secure, and to assist us in complying with our obligations.
7. International transfers
7.1 Some of our service providers are established outside the European Economic Area, or process personal data outside the EEA. Where personal data is transferred outside the EEA, we ensure a similar degree of protection by relying on one of the following safeguards:
(a) transfer to a country in respect of which the European Commission has made an adequacy decision under Article 45 of the GDPR (this currently includes, among others, the United Kingdom, Switzerland, and the United States in respect of organisations certified under the EU–US Data Privacy Framework); or
(b) the European Commission’s Standard Contractual Clauses under Article 46 of the GDPR, supplemented where necessary by a transfer impact assessment and additional technical and organisational measures.
7.2 You may request a copy of the relevant safeguard by contacting us at elle@antiparosadvisory.com. We may need to redact commercially confidential terms.
8. How long we keep your personal data
8.1 We keep personal data only for as long as necessary for the purposes for which it was collected, including to satisfy any legal, accounting, regulatory or reporting requirements.
8.2 In some circumstances we may anonymise or aggregate your personal data so that it can no longer be associated with you, in which case we may use that information indefinitely without further notice to you.
8.3 Where we are involved in, or reasonably anticipate, a legal claim or a regulatory investigation, we may retain relevant personal data until the matter is concluded and any applicable limitation period has expired.
9. Your rights
9.1 Under the GDPR you have the following rights in relation to your personal data:
(a) Right of access - to be told whether we process your personal data and to receive a copy of it, together with information about our processing.
(b) Right to rectification - to have inaccurate personal data corrected and incomplete personal data completed.
(c) Right to erasure (“right to be forgotten”) - to have your personal data deleted where there is no good reason for us to continue processing it. This right is not absolute.
(d) Right to restriction of processing - to ask us to suspend processing in certain circumstances, for example while we verify the accuracy of data you have challenged.
(e) Right to data portability - to receive personal data you have provided to us, where we process it on the basis of your consent or a contract and by automated means, in a structured, commonly used and machine-readable format, and to have it transmitted to another controller.
(f) Right to object - to object to processing based on our legitimate interests. Where you object to processing for direct marketing purposes, we will stop that processing.
(g) Right to withdraw consent - where we rely on your consent, to withdraw it at any time. This does not affect the lawfulness of processing carried out before withdrawal.
(h) Right not to be subject to automated decision-making - we do not carry out such decision-making.
9.2 How to exercise your rights. Email us at elle@antiparosadvisory.com, marking your message “Data subject request”. Please tell us which right you wish to exercise and give us enough information to identify you and locate your data.
9.3 Our response. There is no fee for exercising your rights, although we may charge a reasonable fee, or refuse to act, if a request is manifestly unfounded or excessive. We may need to request specific information from you to confirm your identity. We will respond within one month of receipt of your request. If your request is complex, or you have made a number of requests, we may extend this by up to two further months, and we will tell you if we do.
9.4 Complaints. If you are unhappy with how we have handled your personal data, please contact us first so we can try to resolve the matter. You also have the right to lodge a complaint at any time with a supervisory authority. Our lead supervisory authority is:
Commission for Personal Data Protection (Комисия за защита на личните данни) 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria Telephone: +359 2 915 3518 Email: kzld@cpdp.bg Website: www.cpdp.bg
You may also complain to the supervisory authority in the EU Member State of your habitual residence or place of work.
10. How we protect your personal data
10.1 We have put in place technical and organisational measures appropriate to the risk, including encryption of the Site in transit (TLS), access controls and strong authentication on the systems we use, limiting access to personal data to those who need it, and using reputable service providers who commit to appropriate security standards.
10.2 No system is completely secure, and the transmission of information over the internet is never entirely risk-free. We cannot guarantee the security of personal data transmitted to the Site.
10.3 We have procedures to deal with any suspected personal data breach and will notify you and the Commission for Personal Data Protection of a breach where we are legally required to do so.
11. Cookies and similar technologies
11.1 The Site uses cookies and similar technologies. Please see our Cookie Notice for details of what we use, why, and how to control them.
11.2 We only place non-essential cookies (including analytics cookies) with your consent, which you may withdraw at any time.
12. Third-party links
12.1 The Site may contain links to third-party websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control those third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.
13. Changes to this Privacy Policy
13.1 We may update this Privacy Policy from time to time. The current version is always available on the Site, and the “Last updated” date at the top shows when it was last changed.
13.2 Where a change is material, for example, a new purpose of processing or a new category of recipient, we will take reasonable steps to bring it to your attention, which may include notifying subscribers by email.
13.3 We encourage you to review this Privacy Policy periodically.
