Cyprus: How To Ensure Creditor Protection In Cyprus

Last Updated: 25 March 2015
Article by Demetris Loizides

This article outlines the many ways in which under Cypriot law businesses can protect their interests in their commercial dealings.

Any creditor needs to ensure that he will receive payment for the sale of his goods or services, or that his loan will be repaid.

The creditor often relies on the right to bring legal proceedings:

  1. which will result in a judgment debt that can ultimately be enforced by seizing and, if necessary, selling, any of the debtor's assets that the creditor can lay his hands on; and/or
  2. for bankruptcy (if an individual) or a petition for a winding-up (if a company); failure to pay a debt after due demand is an act of bankruptcy or a ground for winding up. But, if the reason for such non-payment is a genuine dispute over the amount of the debt, or if there is counter-claim of some sort, eg a breach of contract on the part of the creditor, the debtor may successfully resist the proceedings/petition, and the court may regard such proceedings/petition an abuse entitling the debtor to an award of his cost in the action against the creditor. However, placing the debtor in bankruptcy or liquidation is a false triumph. Other than the fact that this a time consuming process, all creditors are invited to share in the spoils, which in practice means that a 100 per cent recovery by the creditors is rarely achieved.

The aim therefore is to place the creditor in a position to recover the debt quickly without resorting to bankruptcy or winding up proceedings. Where such proceedings are inevitable, the aim is to place the creditor in a position to recover the debt in full even if the debtor is unable to meet all of his liabilities. The creditor must accordingly make use of the means available either at law or under contract to ensure both payment and priority.

Guarantees

If the debtor does not appear to the creditors to be creditworthy, the creditor may require the debtor to find a guarantor who is financially able. The best guarantor is invariably a bank, and such guarantees can be obtained by commercial customers for a fee.

Guarantees are often obtained by holding companies for the liabilities of their subsidiaries and sister companies. Particularly in the local market, personal guarantees are given for the liabilities of private companies by their directors who are usually also members (commercially speaking, the shareholders).

Liens

Generally, a lien is a creditor's right to retain possession of his debtor's personal property (chattels) until the debtor pays his debt. It confers NO power of sale. Liens can arise from statute (Contract Law, Chapter 149 - Cap 149) or from a contract (including the articles of association of a company). A lien is founded on possession - that is to say, the creditor must obtain possession by lawful means, and not for a purpose inconsistent with a lien (such as to sell). Assets subject to a lien cannot be seized by third parties claiming against their owner, nor can the owner's successors in title obtain possession without paying the debt. The lien thus provides the debtor, and in the event of insolvency or bankruptcy, the debtor's receiver, liquidator or trustee in bankruptcy, with an incentive to pay the debt in full. This incentive is augmented where the property is worth significantly more than the debt in question.

The unpaid seller's lien arises under the Sale of Goods Law, Law 10(I)/1994 (SGL). Even if property (title/ownership) has passed to the buyer, and even if the seller is in possession as the buyer's agent, the seller may retain possession of goods until the seller is paid the price of the goods, provided that the seller has not sold on credit, or, if that is the case, either the period of credit granted has expired, or the buyer has become insolvent. The lien is of course lost if the seller chooses to waive it.

Pledge

A pledge is a type of bailment. Personal property capable of being (actually or constructively) delivered is deposited by the debtor (usually a borrower or a guarantor), the so called pledgor, with the creditor (usually a lender), the so called pledgee and thus delivering possession of the property concerned to the pledgee. The property will be returned upon repayment of the debt (or the discharge of some other liability).

Unlike a lien, a pledge confers not only possession but also the right of sale, the so called power of sale, (and power to confer title/ownership on a purchaser) if repayment is not made and the property is not reclaimed within an agreed period of time. A lien is a personal right and it is not transferable. A pledge is assignable.

In practice today the pledge of shares is a very common form of security in commercial transactions or loans.

(Traditional) mortgage

Under a traditional mortgage of immovable property or personal property, the debtor (usually a borrower or a guarantor) the so called mortgagor, remains in possession of the mortgaged property. A legal mortgage transfers title/ownership in the property to the creditor (usually a lender), the so called mortgagee, together with a combined power of foreclosure and sale upon a default in repayment. This power is vested by the instrument creating the mortgage. On redemption (ie repayment), title/ownership is vested back to the mortgagor.

An equitable mortgage may be created:

  1. by an express document agreeing, under certain circumstances (eg an event of default), to transfer the legal title/ownership in the property to the creditor (Equitable Mortgage A); or
  2. by way of deposit of the instruments/documents of title/ownership to the relevant property (such as a blank (but otherwise executed by the transferor) instrument of transfer of shares/debentures, or share/debenture certificates) with the creditor (Equitable Mortgage B).

On default, under either type of equitable mortgage, the lender has the right, in equity, to compel the debtor to convey to the creditor legal title/ownership in the property for the purposes of sale. Upon repayment the agreement is terminated (in the case of Equitable Mortgage A) or the instruments are returned as appropriate (in the case of Equitable Mortgage B). Equitable Mortgage A and Equitable Mortgage B are not mutually exclusive; they may coexist in relation to the same property in favour of the same mortgagee.

There is a notable distinction between:

  1. documents/instruments deposited as security for the debt (or some other liability) which are certificates (ie evidence of title/ownership); and
  2. documents deposited as security for the debt (or some other liability) which EITHER give the possessor the right to take immediate possession of the relevant property OR the deposit of such documents itself transfers title/ownership to a chose in action, such as bearer bonds or bearer shares, or other negotiable instruments payable or endorsed to bearer (eg promissory notes payable to bearer or endorsed to bearer under the Bill of Exchange Law, Cap 262).

A deposit of documents under (b) may be regarded NOT as an equitable mortgage but as a pledge of the relevant property (goods or chose in action). This distinction is important for it will determine the rights of the secured creditor (including the steps required to exercise disposing powers) but also the steps required to be taken to "perfect" the security (see section below on Registration).

A mortgage differs from a pledge. The mortgagee acquires general title/ownership in the mortgage property, subject to the mortgagor's right to redeem. By a pledge the general title/ownership remains with the pledgor and the pledgee has no right of foreclosure but merely a right to sell. Ultimately the question whether the particular security is a mortgage or a pledge only, will be determined by reference to the intention of the parties and other surrounding circumstances. Nevertheless, there can be a pledge of personal property and also mortgage of personal property. There can be a valid mortgage of personal property, and when not accompanied by delivery of possession, is still operative as a security (mortgage only), save and except against a third party acting in good faith without notice.

An Equitable Mortgage B is still widely used. Such a mortgage coupled with a share pledge is particularly used in relation to shares. However, the traditional mortgage is nowadays becoming increasingly redundant as it is increasingly being replaced by the charge.

Charge

A charge gives the right to the creditor to resort to identified property, immovable property or personal property, to satisfy the debt (or some other liability) if not paid/repaid (or satisfied/discharged). Neither possession nor (unlike a traditional mortgage) title/ownership, passes to the creditor. Instead the creditor may call for the assignment/transfer of the property to the creditor himself if the debt is not paid/repaid or satisfied/discharged when due. The most appropriate remedy is to appoint a receiver who takes control of the property for the purpose of selling it, satisfying the debt, and handing the balance, if any, over to the debtor. It is preferable to appoint such a receiver by the instrument/agreement creating the charge, or if not, a statutory receiver may be appointed (in the case of immovable property) under statute. Indeed a charge is very similar to a mortgage in that it gives all the rights of a mortgagee without the need of transferring possession or ownership.

Charges can arise either as a result of an agreement or by operation of law. In commercial circumstances, the charges arising by operation of law which are most commonly met with, are those imposed under the equitable doctrines and statutory (Cap 149) provisions relating to the tracing of property (and the proceeds thereof) which has been entrusted to a bailee or fiduciary and has been misapplied by him.

Express charges can be either fixed or floating. A fixed charge is created over particular assets (including deposits of cash held in a bank or by another person). In relation to immovable property, an express charge is still termed a "mortgage", but has nevertheless effectively substituted the use of the traditional mortgage.

Apart from immovable property and capital assets, fixed charges are not practical on assets such as merchandise (stock in trade) as these are constantly being replaced (turnover). In such a case, fixed charges would therefore need to be constantly created and released; this is impractical in the least. Instead, a "floating" charge should be created over all the assets of the business from time to time, or perhaps one class of assets, such as book debts or stock in trade. This floating charge 'hovers' over the changing/circulating assets in the course of trading and carrying on business, until a default occurs. The charge then 'crystallises' and attaches to all the assets (or the particular class of assets) held as at that time and a receiver is then appointed to take control of those assets.

Registration

The problem with all forms of charges (fixed or floating or mortgages), whether they are security for commercial transactions or loans, is that the debtor remains in possession of the charged assets. Consequently, the debtor continues to present an appearance of wealth to other (unaware) persons dealing with the debtor. Accordingly, the debtor can "disappear" with the proceeds of the disposal of such assets, leaving the original creditor and the unaware purchaser with a dispute over the assets concerned. A desire to make such charges public in order to avoid fraud, deceit, trickery and similar activity has resulted in the application of the concept of registration.

There are three regimes governing registration of securities, which overlap to some extent. These are generally as follows:

  1. Registration in a statutory registry relating to the asset concerned. This depends on the type or nature of the asset. For example, in relation to security interests over immovable property situated in Cyprus, the relevant statutory registry is the Land Registry. A mortgage created over immovable property in Cyprus by any person (whether an individual or a corporation) is invalid unless it is registered at the Land Registry (s5 of the Immovable Property (Transfer and Mortgage) Law, 1965, Law 9(I)/1965 (L65)). Another example concerns the mortgaging of ships, which are similarly registrable at the Department of Ports of the Ministry of Communications and Works under the Merchant Shipping (Registration of Ships, Sales and Mortgages) Law, 1963, Law 45(I)/1963.
  2. Certain charges (the term includes mortgages) created by a company or created in any other way over its undertaking or over any of its property (immovable or otherwise) are void against the liquidator and any creditors unless registered with the Registrar of Companies – ss90–97 of the Companies Law, Chapter 113 of the statute laws of the Republic of Cyprus (Cap 113). This applies to companies incorporated or liable to be wound up under Cap 113.
  3. All charges (the term includes mortgages) created by a company over its assets must also be registered in the register of charges or mortgage book which are part of the company's statutory books (ss98–100 Cap 113). This requirement is wider than that under ss90–97 Cap 113. However, the effect of not doing so does not invalidate the charge in any way, but renders the directors in default liable to a fine.

The overlap arises where the charge (the term includes a mortgage) in question should be registered:

  1. at the statutory registry (whether the property belongs to an individual or a corporation);
  2. at the Registrar of Companies; and
  3. in the company's statutory books.

Charges must always be registered in the company's statutory books, and, depending upon their nature and the property concerned, may also require registration at the Registrar of Companies as well as at some other statutory registry (eg the Land Registry in the case of immovable property).

Although a legal mortgage/charge over immovable property can only be created by a written instrument, an equitable mortgage over immovable property can be created either by a written instrument or other express document, or by deposit of certificates of title/ownership (title deeds). It is noteworthy that under L65, a mortgage over immovable property must be registered at the Land Registry or else it will be invalid against all persons (including the mortgagor and mortgagee as well as the liquidator, trustee in bankruptcy, official receiver and any creditor or third party). By contrast, failure to register under Cap 113 will render the mortgage/charge void only against the liquidator and any creditors, but the guarantee or the liability upon which the security was created and the security interest per se (and thus the disposing powers under it), remain valid as between the mortgagor/chargor and the mortgagee/chargee.

In theory, any mortgage or charge of personal property can be created orally (and perhaps later evidenced in writing) and an equitable mortgage of personal property can also be created by depositing the relevant documents of title/ownership (see above "Equitable Mortgage B"). These security interests are caught by the statute as charges which require registration, for s90 Cap 113 makes reference to the creation of the charge not the manner in which it is created. However, although the term 'charge' is very wide, s90 Cap 113 is quite prescriptive as to the types of property over which charges must be registered. These are the following (s90(2) Cap 113):

  1. a charge for the purpose of securing any issue of debentures;
  2. a charge on uncalled share capital of the company;
  3. a charge on book debts of the company;
  4. a floating charge on the undertaking or property of the company;
  5. a charge on calls on shares made but not paid [in respect of partly paid shares];
  6. a charge on a ship or any share in a ship;
  7. a charge on goodwill, on a patent or a licence under a patent, on a trade mark or on a copyright or a licence under a copyright;
  8. a charge on any other movable property created or evidenced by an instrument where the company retains possession of such property;
  9. a charge on immovable property, wherever situate[d], or any interest therein.

In circumstances where the lender/chargee is not certain whether a particular security interest falls within the scope of the above prescribed charges, it is nevertheless advisable to procure, or insist on, the registration of the security interest if at all possible. This is of particular relevance to a security in the form of a pledge of shares. It is submitted that since possession of the pledged property is delivered to the pledgee, the pledgor does not retain possession of the pledged property and therefore the security of pledge falls outside the scope of s90(2)(h) and as such it is not a charge to which s90 applies or which otherwise requires registration.

Some practitioners interpret "possession" by reference to the ability of the pledgor to exercise some form of control over or in respect of the pledged shares (other than disposing powers), such as voting powers/rights derived from the shares per se (as class right) or the ownership of the shares. We do not share the same view. Nevertheless, such powers/rights of control can be restricted entirely in the contract of pledge thereby depriving the pledgor from these rights or powers and any kind of possession.

A recent amendment to s90 attempted to clarify that the security of share pledge does not require registration by expressly excluding the application of s90 to such pledge. However, this amendment led to further uncertainty causing many practitioners to continue advising in favour of the registration of share pledges.

In our view, the position would have been settled had the amendment instead focused on the meaning of possession. Nevertheless, the amendment is a statement of the existing legal position that a share pledge does not require registration.

Retention of title clauses

The right of retaining the title/ownership in the goods sold arises under s19 of the SGL, pursuant to which the property (ie the title/ownership) in the goods passes to the buyer at such time as the parties intend for it to pass. Thus SGL, s19 permits the seller to delay the passing of title/ownership pursuant to the contract, even after delivery has taken place, until a specific condition (in this case payment for the goods) has been fulfilled. Hence the existence of retention of title clauses in contracts for the sale of goods.

Retention of title clauses are useful in situations of insolvency. The seller can recover the goods as the goods belong to the seller and therefore the seller has priority in relation to those goods to other creditors of the buyer. A practical result of this is that the seller does not have to prove the debt owed to him in the insolvency proceedings together with other ordinary (non-secured) creditors.

Such clauses are most useful when dealing with easily identifiable goods. In such a case, simple clauses such as the following will suffice: "Property in the goods will remain with the seller and shall not pass until payment in full for the goods has been received by the seller".

There are ancillary provisions which may supplement the retention of title clause. These include provisions to the effect that the risk passes to the buyer on delivery even though the property (title/ownership) itself does not; that the seller has the right to enter the buyer's premises to repossess the goods; and that the buyer must insure the goods against loss or damage.

A significant problem presented by the use of retention of title clauses arises from the fact that under the SGL (s30), Cap 149 (see sections on Bailment (Part XII) and Agency (Part XIII)) and principles of estoppel, the buyer of goods – notwithstanding the existence of a retention of title clause – is still able to pass valid title to a third party who acts in good faith and without notice of the retention clause (or the retention itself). Problems will also arise where the buyer mixes or uses the goods in the normal course of business. In such a case the seller will want (and accordingly will need to provide for in the contract) rights to enable the seller to trace the proceeds of sale or the goods in their new form.

An effective retention of title clause should retain the entire property (title/ownership) in the goods; reserving/retaining merely a beneficial/equitable interest in the goods will create an equitable charge which must be registered against the buyer (if a company) under s90 Cap 113, or else it will be void against the liquidator or any creditor of the buyer.

An unpaid seller who has delivered goods under a retention of title clause cannot, under s56(1) SGL, sue for the price, since under s56(1) the seller can only sue for the price when title has passed to the buyer unless pursuant to s56(2) SGL, the price has to be paid on a 'defined day'. This problem can therefore be avoided by expressly imposing an obligation on the buyer to pay the price on a specified date.

Creditors are afforded a multitude of options to protect their interests, particularly where the debtor concerned is a company and therefore has public registers available to be searched. Even in the case of individual debtors, with the exception of specific security-interests which must by virtue of a statute be registered to offer full security to the creditor (for example a mortgage on land), creditors are also afforded protection even in the case of a non-registrable charge of an asset (where there is no statutory registry available) against a debtor who is an individual. Such a charge will nonetheless be recognised by the trustee in bankruptcy/official receiver, under the Bankruptcy Law Cap 5. The registration system in itself is a mechanism which provides business and the wider public with a venue to ascertain the encumbrances accompanying an asset. Ultimately, especially since businesses are mostly carried on by companies, creditors benefit from heightened protection to ensure they will be able to recover payment, in turn enabling business transactions to unfold with certainty and allowing transactions to be more streamlined.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
 
Some comments from our readers…
“The articles are extremely timely and highly applicable”
“I often find critical information not available elsewhere”
“As in-house counsel, Mondaq’s service is of great value”

Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.

Disclaimer

Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.

Registration

Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

Cookies

A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Links

This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

Mail-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

Security

This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.