Disclosures

Last updated: June 2026

1. Nature of Services

SPM Family Office provides independent advisory and structuring services to private clients, families and entrepreneurs operating across multiple jurisdictions. Our practice focuses on cross-border residency planning, asset structuring, corporate organisation and investment advisory. All services are provided pursuant to a written engagement letter that defines the scope, terms and limitations of our work.

2. Not a Regulated Financial Institution

SPM Family Office is an independent advisory practice. We are not a bank, licensed investment firm, asset manager, law firm or insurance provider. We do not hold or manage client funds, and we do not provide regulated financial services as defined under MiFID II or equivalent legislation. Where regulated services are required, we coordinate with, and introduce clients to, appropriately licensed professionals in the relevant jurisdiction.

3. No Investment Advice or Solicitation

Nothing on this website, or in any general communication from SPM, constitutes investment advice, a recommendation, an offer, or a solicitation to buy or sell any financial instrument or to enter into any transaction. Any references to structures, jurisdictions or approaches are illustrative and general in nature, and do not take account of your individual circumstances.

4. Independence and No Undisclosed Compensation

SPM operates on a fee-for-service basis. We do not receive commissions, referral fees or undisclosed compensation from third-party service providers. All referrals to external counsel, banks or corporate service providers are made solely on the basis of professional judgement and the client’s interest.

5. Jurisdictional Scope

Our advisory services operate across Cyprus, Liechtenstein and Switzerland. Advice on legal and tax matters in these jurisdictions is provided in coordination with locally licensed legal and tax professionals. We do not hold ourselves out as providing jurisdiction-specific legal or tax advice independently of such professionals.

6. No Guarantee of Outcomes

All structuring and planning work is based on the law, regulation and administrative practice in force at the time of engagement. Laws and their interpretation change, and no guarantee is made as to the future treatment of any structure, residency status or tax position. Past results achieved for other clients are not indicative of future outcomes.

7. Forward-Looking Statements

Any forward-looking statements, projections or expectations referenced in our materials are inherently uncertain and subject to change. They should not be relied upon as a promise or guarantee of any future result.

8. Anti-Money-Laundering and Client Due Diligence

Where we accept an engagement, we are required to perform client due diligence and to comply with applicable anti-money-laundering (“AML”) and counter-terrorist-financing obligations. We may be required to obtain and verify identity and source-of-funds information before or during an engagement.

9. Conflict of Interest Policy

We maintain a formal conflict-of-interest policy. Where a potential conflict is identified, it is disclosed to the client before the engagement proceeds. Clients retain the right to seek independent advice at any stage.

10. Confidentiality

We treat all client information as strictly confidential and disclose it only as necessary to provide the services requested, or where required by law or regulation, in accordance with our Privacy Policy and applicable professional obligations.

11. Contact

For questions about these disclosures, please contact [email protected].

================================================================

Implementation checklist (developer / GTM)

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  1. Consent banner loads first. No GA4 / Clarity / Google Ads tag fires before the visitor opts in via Cookiebot.
  2. Google Consent Mode v2 in GTM: ad_storage, analytics_storage, ad_user_data, ad_personalization default to denied, updated on Cookiebot consent (required to keep Google Ads conversions/audiences working in the EEA).
  3. Map tags to consent categories: GA4 + Clarity → Statistics; Google Ads → Marketing.
  4. Embed the live Cookiebot Cookie Declaration on the Cookie Policy page (script in Cookie Policy §9); replace {YOUR-CBID}.
  5. Run a Cookiebot scan and confirm every detected cookie is categorised (no “Unclassified”).
  6. Resolve the email inconsistency — use [email protected] consistently on spm.family (the source material also mentioned [email protected]).
  7. Footer links: Privacy Policy · Cookie Policy · Legal Notice · Terms of Use · Disclosures · “Cookie settings” (reopens the Cookiebot dialog).
  8. Localisation: if you publish a RU version of these pages, keep the EN and RU versions in sync; the EN version governs in case of conflict (state this).

Get in touch

Request a Consultation

Every engagement begins with a focused assessment. We respond within two business days.

We respond to all qualified enquiries within two business days.

LEGAL NOTICE / IMPRINT
Last updated: June 2026

1. Website Operator

This website (spm.family) is provided and operated by:

Polivar Management LTD (trading as SPM Family Office) Marimax Business Center, Dimokratias Ave 44, Office 104/1st Floor, Paphos 8028, Cyprus Company registration number: HE368516 VAT number: CY10368516R Director / authorised representative: Serhii Polivar Email: [email protected]

2. Responsibility for Content

S. Polivar Management LTD is responsible for the content published on this website. We prepare content with reasonable care; however, see the disclaimers below and our Terms of Use and Disclosures pages.

3. Nature of the Service

SPM Family Office is an independent advisory and structuring practice. It is not a bank, licensed investment manager, law firm or insurance provider, and does not provide regulated financial services. The full regulatory statement is set out on our Disclosures page.

4. Disclaimer for Content

The information on this website is provided for general information only and is subject to change. We do not warrant that the content is complete, accurate or up to date, and it does not constitute legal, tax, financial or investment advice.

5. Disclaimer for External Links

This website may contain links to external websites operated by third parties. We have no control over, and accept no responsibility for, the content, accuracy or availability of such external sites. The inclusion of any link does not imply endorsement.

6. Intellectual Property

All content on this website — including text, design, layout, graphics and logos — is the property of S. Polivar Management LTD or its licensors and is protected by applicable intellectual property laws. It may not be reproduced, distributed or otherwise used without our prior written consent.

7. Online Dispute Resolution

The European Commission provides a platform for online dispute resolution (ODR) at ec.europa.eu/consumers/odr. We are not obliged, and do not undertake, to participate in dispute-resolution proceedings before a consumer arbitration board.

8. Applicable Law

This Legal Notice and the use of this website are governed by the laws of the Republic of Cyprus, as further set out in our Terms of Use.

COOKIE
Last updated: June 2026

1. Introduction

This Cookie Policy explains how S. Polivar Management LTD (trading as SPM Family Office) uses cookies and similar technologies on spm.family, what categories we use, and how you can control them. It should be read together with our Privacy Policy, which explains how we handle the personal data collected through these technologies.

2. What Are Cookies and Similar Technologies

Cookies are small text files placed on your device when you visit a website. They allow the site to recognise your device, remember your choices, and — where you consent — measure usage and support advertising.

We also use technologies that work in a similar way, collectively referred to as “cookies” in this Policy:

  • Pixels / tags — small pieces of code used to record activity (e.g. that a page was viewed or a conversion occurred);
  • Local storage — a browser mechanism used to store information on your device;
  • Software development kits and similar tools embedded by our analytics and advertising providers.

Cookies can be distinguished by durationsession cookies (deleted when you close your browser) and persistent cookies (remaining until they expire or are deleted) — and by originfirst-party cookies (set by spm.family) and third-party cookies (set by our service providers, such as Google and Microsoft).

3. Why We Use Cookies

We use cookies to: (a) make the Website function and remain secure; (b) remember your preferences; (c) understand how visitors use the Website so we can improve it; and (d) measure and optimise our advertising.

4. Legal Basis and Your Consent

In accordance with the ePrivacy Directive and the GDPR, strictly necessary cookies are set without consent because they are essential for the Website to operate. All other cookies — preferences, statistics/analytics and marketing — are set only on the basis of your prior consent (Article 6(1)(a) GDPR).

When you first visit the Website, our consent banner — provided by Cookiebot — asks you to choose which categories you allow. We use Google Consent Mode in Google Tag Manager, so analytics and advertising tags do not collect or transmit data until the relevant consent has been given. You can change or withdraw your consent at any time (see Section 7).

5. Categories of Cookies We Use

Strictly necessary — required for the Website to function (security, load balancing, and storing your cookie-consent choices). These do not require consent.

Preferences — remember choices you make (such as language) to provide enhanced, personalised features.

Statistics / Analytics — help us understand how visitors interact with the Website, on an aggregated basis, so we can improve it. Set only with your consent.

Marketing / Advertising — used to measure the effectiveness of, and to deliver and optimise, our advertising; and, where applicable, to build audiences. Set only with your consent.

6. Detailed List of Cookies

The tables below describe the principal cookies used on the Website. The authoritative, automatically updated list — including any cookies not shown here — is generated by Cookiebot and displayed via the Cookie Declaration (see Section 9). Durations are indicative and may vary by provider configuration.

6.1 Strictly necessary

Cookie

Provider

Purpose

Duration

CookieConsent

Cookiebot (spm.family)

Stores your cookie-consent state for the current domain

1 year

6.2 Statistics / Analytics (set only after consent)

Cookie

Provider

Purpose

Duration

_ga

Google Analytics 4

Distinguishes unique users

~2 years

_ga_<container-id>

Google Analytics 4

Persists session state for GA4

~2 years

_gid

Google Analytics

Distinguishes users

24 hours

_gat / _gat_*

Google Analytics

Throttles request rate

1 minute

_clck

Microsoft Clarity

Persists the Clarity user ID and preferences

1 year

_clsk

Microsoft Clarity

Connects multiple page views into a single session recording

1 day

CLID

Microsoft Clarity

Identifies the first time Clarity saw this user on the site

1 year

ANONCHK

Microsoft (Clarity/Bing)

Indicates whether the MUID identifier is used for analytics

10 minutes

MR

Microsoft (Clarity/Bing)

Indicates whether to refresh the MUID identifier

7 days

MUID

Microsoft (Clarity/Bing)

Identifies unique browsers for analytics and operational purposes

~1 year

SM

Microsoft (Clarity)

Synchronises the MUID identifier across Microsoft domains

Session

Cookie

Provider

_ga

Google Analytics 4

_ga_<container-id>

Google Analytics 4

_gid

Google Analytics

_gat / _gat_*

Google Analytics

_clck

Microsoft Clarity

_clsk

Microsoft Clarity

CLID

Microsoft Clarity

ANONCHK

Microsoft (Clarity/Bing)

MR

Microsoft (Clarity/Bing)

MUID

Microsoft (Clarity/Bing)

SM

Microsoft (Clarity)

Purpose

Duration

Distinguishes unique users

~2 years

Persists session state for GA4

~2 years

Distinguishes users

24 hours

Throttles request rate

1 minute

Persists the Clarity user ID and preferences

1 year

Connects multiple page views into a single session recording

1 day

Identifies the first time Clarity saw this user on the site

1 year

Indicates whether the MUID identifier is used for analytics

10 minutes

Indicates whether to refresh the MUID identifier

7 days

Identifies unique browsers for analytics and operational purposes

~1 year

Synchronises the MUID identifier across Microsoft domains

Session

Microsoft Clarity also provides heatmaps and session recordings (clicks, scrolling and mouse movement). Clarity applies automatic masking to input fields; we do not use it to capture the content you type into forms.

6.3 Marketing / Advertising (set only after consent)

Cookie

Provider

Purpose

Duration

_gcl_au

Google Ads (Conversion Linker)

Stores and tracks ad-click conversions

3 months

IDE

Google (doubleclick.net)

Measures and reports on ad performance; remarketing

~1 year

test_cookie

Google (doubleclick.net)

Checks whether the browser supports cookies

1 day

_gcl_*
(variants)

Google Ads

Conversion attribution

Up to 3 months

Cookie

Provider

_gcl_au

Google Ads (Conversion Linker)

IDE

Google (doubleclick.net)

test_cookie

Google (doubleclick.net)

_gcl_*
(variants)

Google Ads

Purpose

Duration

Stores and tracks ad-click conversions

3 months

Measures and reports on ad performance; remarketing

~1 year

Checks whether the browser supports cookies

1 day

Conversion attribution

Up to 3 months

7. How to Manage or Withdraw Your Consent

  • On the Website: reopen the cookie settings at any time via the cookie/consent link (provided by Cookiebot) to change or withdraw your choices.
  • In your browser: you can block or delete cookies through your browser settings. Helpful guides are available for the major browsers:
    • Google Chrome — support.google.com/chrome/answer/95647
    • Mozilla Firefox — support.mozilla.org
    • Apple Safari — support.apple.com
    • Microsoft Edge — support.microsoft.com
  • Provider opt-outs: Google Analytics opt-out — tools.google.com/dlpage/gaoptout; Google Ads settings — adssettings.google.com.

8. "Do Not Track" and Global Privacy Control

Some browsers offer “Do Not Track” (DNT) or Global Privacy Control (GPC) signals. As there is currently no uniform industry standard for how these signals must be handled, our primary mechanism for honouring your choices is the Cookiebot consent banner described above.

9. Cookie Declaration (live list)

To keep the cookie list accurate and in sync with each scan, embed the Cookiebot Cookie Declaration on this page:

				
					<script id="CookieDeclaration"
        src="https://consent.cookiebot.com/{YOUR-CBID}/cd.js"
        type="text/javascript" async></script>

				
			

10. Third-Party Information

For details of how our providers process data, see: Google Privacy Policy — policies.google.com/privacy; Microsoft Privacy Statement — privacy.microsoft.com; Cookiebot/Usercentrics — usercentrics.com.

11. Consequences of Disabling Cookies

If you decline non-essential cookies, the Website will continue to function, but some features may be limited and we will be unable to measure and improve your experience or the effectiveness of our communications.

12. Changes and Contact

We may update this Cookie Policy from time to time; the “Last updated” date reflects the current version. Questions can be sent to [email protected].

Disclosures
Last updated: June 2026

1. Nature of Services

SPM Family Office provides independent advisory and structuring services to private clients, families and entrepreneurs operating across multiple jurisdictions. Our practice focuses on cross-border residency planning, asset structuring, corporate organisation and investment advisory. All services are provided pursuant to a written engagement letter that defines the scope, terms and limitations of our work.

2. Not a Regulated Financial Institution

SPM Family Office is an independent advisory practice. We are not a bank, licensed investment firm, asset manager, law firm or insurance provider. We do not hold or manage client funds, and we do not provide regulated financial services as defined under MiFID II or equivalent legislation. Where regulated services are required, we coordinate with, and introduce clients to, appropriately licensed professionals in the relevant jurisdiction.

3. No Investment Advice or Solicitation

Nothing on this website, or in any general communication from SPM, constitutes investment advice, a recommendation, an offer, or a solicitation to buy or sell any financial instrument or to enter into any transaction. Any references to structures, jurisdictions or approaches are illustrative and general in nature, and do not take account of your individual circumstances.

4. Independence and No Undisclosed Compensation

SPM operates on a fee-for-service basis. We do not receive commissions, referral fees or undisclosed compensation from third-party service providers. All referrals to external counsel, banks or corporate service providers are made solely on the basis of professional judgement and the client’s interest.

5. Jurisdictional Scope

Our advisory services operate across Cyprus, Liechtenstein and Switzerland. Advice on legal and tax matters in these jurisdictions is provided in coordination with locally licensed legal and tax professionals. We do not hold ourselves out as providing jurisdiction-specific legal or tax advice independently of such professionals.

6. No Guarantee of Outcomes

All structuring and planning work is based on the law, regulation and administrative practice in force at the time of engagement. Laws and their interpretation change, and no guarantee is made as to the future treatment of any structure, residency status or tax position. Past results achieved for other clients are not indicative of future outcomes.

7. Forward-Looking Statements

Any forward-looking statements, projections or expectations referenced in our materials are inherently uncertain and subject to change. They should not be relied upon as a promise or guarantee of any future result.

8. Anti-Money-Laundering and Client Due Diligence

Where we accept an engagement, we are required to perform client due diligence and to comply with applicable anti-money-laundering (“AML”) and counter-terrorist-financing obligations. We may be required to obtain and verify identity and source-of-funds information before or during an engagement.

9. Conflict of Interest Policy

We maintain a formal conflict-of-interest policy. Where a potential conflict is identified, it is disclosed to the client before the engagement proceeds. Clients retain the right to seek independent advice at any stage.

10. Confidentiality

We treat all client information as strictly confidential and disclose it only as necessary to provide the services requested, or where required by law or regulation, in accordance with our Privacy Policy and applicable professional obligations.

11. Contact

For questions about these disclosures, please contact [email protected].

Terms
Last updated: June 2026

1. Introduction and Acceptance

These Terms of Use (“Terms”) govern your access to and use of the website spm.family (the “Website”), operated by S. Polivar Management LTD, trading as SPM Family Office (“SPM”, “we”, “us”). By accessing or using the Website, you agree to be bound by these Terms. If you do not agree, please do not use the Website.

2. About Us

S. Polivar Management LTD is a company incorporated in the Republic of Cyprus (registration number HE368516; VAT CY10368516R), with its registered office at Marimax Business Center, Dimokratias Ave 44, Office 104/1st Floor, Paphos 8028, Cyprus.

3. Eligibility

The Website is intended for adults seeking information about our advisory services. By using it, you confirm that you are at least 18 years old and legally able to enter into these Terms.

4. Informational Purpose Only — No Advice

The Website is provided for general informational purposes only. Nothing on the Website constitutes, or should be relied upon as, legal, tax, financial, investment or other professional advice. You should obtain professional advice tailored to your specific circumstances before taking, or refraining from, any action.

5. No Client Relationship

Accessing the Website or submitting an enquiry does not create a client, advisory or fiduciary relationship with SPM. A formal engagement arises only upon the execution of a written engagement letter signed by both parties. Information you submit through the Website is treated in accordance with our Privacy Policy, but submitting it does not oblige us to provide services.

6. Permitted Use

You may use the Website for lawful, personal and business-informational purposes, in accordance with these Terms and all applicable laws.

7. Prohibited Use

You agree not to:

  • use the Website in any way that is unlawful, fraudulent or harmful;
  • attempt to gain unauthorised access to the Website, its servers or any connected systems;
  • introduce viruses, malware or other malicious code;
  • interfere with or disrupt the integrity or performance of the Website;
  • scrape, harvest or collect data from the Website by automated means without our consent;
  • reproduce, copy or exploit any part of the Website for commercial purposes without our prior written consent;
  • misrepresent your identity or affiliation.

8. Intellectual Property

All content on the Website — including text, design, layout, graphics, logos and structure — is owned by S. Polivar Management LTD or its licensors and is protected by intellectual property laws. Except as expressly permitted, you may not reproduce, distribute, modify, publish or use any content without our prior written consent. All rights not expressly granted are reserved.

9. Information You Submit

You are responsible for ensuring that any information you submit through the Website is accurate and that you are entitled to provide it. You should not submit confidential or sensitive information through the enquiry form beyond what is necessary to describe your initial request.

10. Accuracy and Availability

We make reasonable efforts to ensure the Website is accurate and available, but we do not warrant that it will be uninterrupted, error-free, or that defects will be corrected. Laws, regulations and market conditions change, and content may become out of date. We may modify, suspend or discontinue any part of the Website at any time without notice.

11. Third-Party Links

The Website may contain links to third-party websites. We are not responsible for the content, accuracy or practices of any third-party website, and the inclusion of any link does not imply endorsement.

12. Disclaimer of Warranties

To the fullest extent permitted by applicable law, the Website and its content are provided “as is” and “as available”, without warranties of any kind, whether express or implied, including warranties of accuracy, merchantability, fitness for a particular purpose, or non-infringement.

13. Limitation of Liability

To the fullest extent permitted by applicable law, SPM and S. Polivar Management LTD shall not be liable for any direct, indirect, incidental, special, consequential or punitive damages, or any loss of profits, data, goodwill or other intangible losses, arising out of or in connection with your use of, or inability to use, the Website or its content. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law.

14. Indemnification

You agree to indemnify and hold harmless SPM and S. Polivar Management LTD, and their directors and personnel, from any claims, losses or expenses arising out of your breach of these Terms or your unlawful use of the Website.

15. Privacy

Your use of the Website is also governed by our Privacy Policy and Cookie Policy, which are incorporated into these Terms by reference.

16. Changes to These Terms

We may update these Terms from time to time. The “Last updated” date indicates the current version. Your continued use of the Website after changes take effect constitutes acceptance of the revised Terms.

17. Severability and Waiver

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will continue in full force and effect. Our failure to enforce any provision is not a waiver of our right to do so later.

18. Entire Agreement

These Terms, together with the Privacy Policy, Cookie Policy, Legal Notice and Disclosures, constitute the entire agreement between you and us regarding your use of the Website.

19. Governing Law and Jurisdiction

These Terms are governed by the laws of the Republic of Cyprus. Any disputes arising out of or in connection with these Terms or the Website shall be subject to the exclusive jurisdiction of the courts of Cyprus, without prejudice to any mandatory consumer-protection rights you may have in your country of residence.

20. Contact

Questions about these Terms may be sent to [email protected], or to S. Polivar Management LTD at the address above.

Privacy
Last updated: May 2026

1. Introduction

This Privacy Policy explains how S. Polivar Management LTD, trading as SPM Family Office ("SPM", "we", "us", "our"), collects, uses, discloses and protects personal data when you visit spm.family (the "Website"), submit an enquiry, or otherwise interact with us through this Website.

We take the protection of your personal data seriously. This Policy is intended to give you a clear and complete picture of our data practices, in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and applicable national law. Where you are located in Switzerland, your equivalent rights under the Swiss Federal Act on Data Protection (FADP) are also respected.

Please read this Policy together with our Cookie Policy, which forms part of it and describes in detail the cookies and tracking technologies used on the Website.

2. Who We Are — Data Controller

The data controller responsible for the processing of your personal data is:

S. Polivar Management LTD (trading as SPM Family Office) Marimax Business Center, Dimokratias Ave 44, Office 104/1st Floor, Paphos 8028, Cyprus Company registration number: HE368516 VAT number: CY10368516R Director: Serhii Polivar Email for data protection matters: [email protected]

SPM is a cross-border advisory and structuring practice operating across Cyprus, Liechtenstein and Switzerland. As the controller is established in the European Union, the GDPR is the primary framework governing this Policy.

3. Definitions

For clarity, certain terms used in this Policy have the meaning given in the GDPR, including: "personal data" (any information relating to an identified or identifiable natural person); "processing" (any operation performed on personal data); "controller" (the party determining the purposes and means of processing); "processor" (a party processing data on behalf of the controller); and "data subject" (the individual to whom the personal data relates — i.e. you).

4. The Personal Data We Collect

We collect personal data in the following ways.

4.1 Data you provide to us directly. When you complete the consultation enquiry form, send us an email, or otherwise communicate with us, we collect:

  • identity data — your name;
  • contact data — your email address and telephone number;
  • enquiry content — any information you choose to include in your message, which may describe your circumstances or objectives.

We ask that you do not include unnecessary sensitive information in free-text fields. We do not seek to collect special categories of data (such as data revealing health, political opinions, or religious beliefs) through the Website.

4.2 Data collected automatically. Subject to your consent where required (see Section 6 and our Cookie Policy), we and our service providers collect:

  • technical data — IP address, device type, operating system, browser type and settings, and language preferences;
  • usage data — pages visited, time spent, scroll depth, clicks, navigation paths, referring website or campaign, and similar interaction data;
  • session/usability data — where session-analytics tools are active, recordings of mouse movement, scrolling and clicks for the purpose of improving usability (input fields are masked, as described in the Cookie Policy).

4.3 Server logs. Our hosting infrastructure automatically records standard technical information (such as IP address, timestamp, requested resource and HTTP status) for security, troubleshooting and integrity purposes.

5. Purposes of Processing and Legal Bases

We process personal data only where we have a lawful basis to do so under Article 6 GDPR. The table below sets out each purpose and its corresponding legal basis.

#

Purpose

Categories of data

Legal basis (Art. 6 GDPR)

a

To receive and respond to your enquiry, and to assess whether and how we can assist you

Identity, contact, enquiry content

Steps taken at your request prior to a possible engagement — Art. 6(1)(b); and/or our legitimate interest in responding to enquiries — Art. 6(1)(f)

b

To communicate with you regarding your enquiry or a prospective engagement

Identity, contact, enquiry content

Art. 6(1)(b) and/or Art. 6(1)(f)

c

To measure and improve the performance, content and usability of the Website (analytics and session analysis)

Technical, usage, session/usability

Your consent — Art. 6(1)(a)

d

To operate and measure our advertising, including campaign performance and audience building

Technical, usage, conversion

Your consent — Art. 6(1)(a)

e

To maintain the security, availability and integrity of the Website and to prevent abuse

Technical, server logs

Our legitimate interest — Art. 6(1)(f)

f

To comply with legal, regulatory and professional obligations, and to establish, exercise or defend legal claims

As relevant

Legal obligation — Art. 6(1)(c); and/or legitimate interest — Art. 6(1)(f)

#

Purpose

a

To receive and respond to your enquiry, and to assess whether and how we can assist you

b

To communicate with you regarding your enquiry or a prospective engagement

c

To measure and improve the performance, content and usability of the Website (analytics and session analysis)

d

To operate and measure our advertising, including campaign performance and audience building

e

To maintain the security, availability and integrity of the Website and to prevent abuse

f

To comply with legal, regulatory and professional obligations, and to establish, exercise or defend legal claims

#

Categories of data

a

Identity, contact, enquiry content

b

Identity, contact, enquiry content

c

Technical, usage, session/usability

d

Technical, usage, conversion

e

Technical, server logs

f

As relevant

#

Legal basis (Art. 6 GDPR)

a

Steps taken at your request prior to a possible engagement — Art. 6(1)(b); and/or our legitimate interest in responding to enquiries — Art. 6(1)(f)

b

Art. 6(1)(b) and/or Art. 6(1)(f)

c

Your consent — Art. 6(1)(a)

d

Your consent — Art. 6(1)(a)

e

Our legitimate interest — Art. 6(1)(f)

f

Legal obligation — Art. 6(1)(c); and/or legitimate interest — Art. 6(1)(f)

Where our basis is legitimate interest, we have balanced that interest against your rights and freedoms; you may object to such processing as described in Section 11.

6. Cookies and Tracking Technologies

The Website uses cookies and similar technologies. Strictly necessary cookies are essential for the Website to function and are set without consent. All non-essential cookies — including analytics (Google Analytics 4, Microsoft Clarity) and advertising (Google Ads) — are set only after you give consent via our consent banner, which is operated by Cookiebot. You may grant, refuse, or withdraw consent at any time, without detriment.

We deploy our tags through Google Tag Manager, configured with Google Consent Mode, so that analytics and advertising tags do not collect or transmit data until the corresponding consent has been granted.

A full description of each category, the specific tools, and the individual cookies (with their purposes and durations) is set out in our Cookie Policy.

7. Marketing Communications

We do not use enquiry data to send unsolicited marketing. If, in the future, we offer the option to subscribe to updates, we will only send such communications on the basis of your consent, and every message will include an option to unsubscribe.

8. Disclosure of Personal Data — Recipients and Processors

We disclose personal data only where necessary and subject to appropriate safeguards. The categories of recipients are:

8.1 Professional advisors and counsel. Where required to provide services you have requested, we may share information with legal, tax and other professional advisors in the relevant jurisdictions. All such parties are bound by strict confidentiality and, where applicable, professional secrecy obligations.

8.2 Technology service providers (processors) acting on our behalf and under data processing agreements:

  • Google Ireland Ltd / Google LLC — Google Tag Manager, Google Analytics 4, Google Ads;
  • Microsoft Corporation — Microsoft Clarity (analytics, heatmaps and session/usability insights);
  • Usercentrics A/S (Cookiebot) — consent management (EU-based);
  • our website hosting and infrastructure provider.

8.3 Public authorities and other third parties where disclosure is required by law, regulation, court order, or to protect our legal rights.

We do not sell personal data, and we do not share it with third parties for their own independent marketing or commercial purposes.

9. International Data Transfers

Some of our service providers (notably Google and Microsoft) are established in, or process data in, the United States. Where personal data is transferred outside the European Economic Area (EEA), we ensure an appropriate transfer mechanism under Chapter V GDPR is in place, namely:

  • the EU–U.S. Data Privacy Framework, where the recipient is certified under it (Google and Microsoft maintain such certifications); and/or
  • the European Commission’s Standard Contractual Clauses (SCCs), supplemented by additional technical and organisational measures where appropriate.

You may request a copy of, or further information about, the relevant safeguards by contacting us at [email protected]. For Swiss-originating data, equivalent mechanisms under the Swiss FADP (including the Swiss–U.S. Data Privacy Framework and the Swiss addendum to the SCCs) apply.

10. Data Retention

We keep personal data only for as long as necessary for the purposes for which it was collected, after which it is securely deleted or anonymised.

Data

Retention period

Enquiry and contact data (no engagement established)

24 months from your last contact, then securely deleted

Engagement / client data

For the duration of the engagement and thereafter for statutory and professional retention periods applicable in the relevant jurisdiction

Analytics data (GA4, Microsoft Clarity)

For the retention periods configured in each tool and the lifetimes of the relevant cookies (see Cookie Policy)

Advertising data (Google Ads)

For the lifetimes of the relevant cookies and the periods configured in the platform

Server logs

Only as long as necessary for security and integrity purposes

11. Your Rights

Under the GDPR (and, for Swiss residents, the FADP), you have the following rights in respect of your personal data:

  • Right of access — to obtain confirmation of whether we process your data and a copy of it;
  • Right to rectification — to have inaccurate or incomplete data corrected;
  • Right to erasure (“right to be forgotten”) — to have your data deleted where one of the grounds in Article 17 GDPR applies;
  • Right to restriction of processing — to limit how we use your data in certain circumstances;
  • Right to data portability — to receive data you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible;
  • Right to object — to object to processing based on legitimate interests, and to object at any time to processing for direct marketing;
  • Right to withdraw consent — where processing is based on consent, you may withdraw it at any time; this does not affect the lawfulness of processing carried out before withdrawal;
  • Right not to be subject to solely automated decision-making producing legal or similarly significant effects (see Section 12).

How to exercise your rights. Please contact us at [email protected]. We may need to verify your identity before responding. We will respond without undue delay and in any event within one month of receipt, which may be extended by a further two months for complex or numerous requests (we will inform you if so). Exercising your rights is free of charge, save where requests are manifestly unfounded or excessive.

Right to complain. Without prejudice to any other remedy, you may lodge a complaint with a supervisory authority, in particular in the EEA Member State of your residence, place of work, or place of the alleged infringement. Our lead supervisory authority is set out in Section 17.

12. Automated Decision-Making and Profiling

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing, including profiling, through the Website. Analytics and advertising tools may segment audiences in aggregate, but this is not used to make decisions about you individually.

13. Children's Privacy

The Website and our services are directed at adults and are not intended for children. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us so we can delete it.

14. Third-Party Links and Social Media

The Website may contain links to third-party websites or resources. We are not responsible for the privacy practices or content of those third parties. We encourage you to review their privacy notices before providing them with personal data.

15. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, loss or destruction. These include encryption of communications in transit (TLS), access controls limiting access to authorised personnel on a need-to-know basis, and ongoing review of our safeguards. No method of transmission over the internet is entirely secure; we cannot guarantee absolute security, but we work to protect your data and to respond appropriately to any incident.

16. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements. The “Last updated” date indicates the current version. Where changes are material, we will take reasonable steps to bring them to your attention.

17. Contact and Supervisory Authority

For any privacy-related enquiry, or to exercise your rights:

Polivar Management LTD — Marimax Business Center, Dimokratias Ave 44, Office 104/1st Floor, Paphos 8028, Cyprus · [email protected]

Our lead supervisory authority is:

Office of the Commissioner for Personal Data Protection (Cyprus) Office address: Kypranoros 15, 1061 Nicosia, Cyprus Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus Tel: +357 22 818 456 · Fax: +357 22 304 565 Email: [email protected] Website: www.dataprotection.gov.cy