Introduction:

This Privacy Policy outlines the data processing practises of GAMH REALTY MANAGER LTD (hereinafter “Realty”), whether concerning individuals (including personal information/data of clients, intermediaries, third parties or any individual associated with them) or otherwise and how the group is complied with its legal obligations to you. 

Realty is fully committed to ensuring that your personal data are protected and in full compliance based on the Cyprus Law providing the Protection of Natural Persons with regard to the Processing of Personal Data and for the free Movement of such data of 2018 [Law 125(I)/2018] (the “Law”) and the European Union General Data Protection Regulation 2016 (“GDPR”).

By accessing or visiting this website, you acknowledge, understand and consent to the collection and processing of your information subject to this Policy. Please read this policy carefully before using the Website or submitting any information.

What personal information we process?

Personal Information that you provide voluntarily 

While using our website, it may be requested to provide with certain identifiable information that can be used in order Realty’s representative to contact you. Personal Data may include, but it is not limited to: 

• Basic information – such as name, surname, date of birth, gender, passport and/or ID information and publicly available photograph;
• Contact information – such as your home address, zip/postal code, email address and phone number;
• Financial information – itemized spending and transaction history;
• Property Related Preferences (Type of Property, Budget, Reason of Investment etc);
• KYC documents; and
• CV and its corresponding cover letters. 

Personal Information that is collected automatically

Usage Data is collected automatically when using Realty’s website. Usage Data may include, but it is not limited to your IP address, operating system, platform, referring URLs, pages visited, hardware model, mobile network, browser plug-in types and versions, time zone setting, the pages visited within the website, the length of time you spend on pages within the website and search terms you used in search engines that results in your linking to the Website.

While the information collected can be linked to the IP address used by your computer during your visit to the Website, it will not be linked to you as an individual or combined with any other information you may submit through the Website, or that we may s about you for any other purposes. This information is solely used for aggregate statistics about visitors to our Website. For further information on the data transmitted by your browser or information by your browser settings, please check your browser’s settings. 

How do we use your personal information

We use your personal information for the following purposes:

• Assisting you with your property search;
• Registering you as a new customer;
• Hosting and arranging viewings, launches and events;
• Facilitating the reservation, purchase, sale or leasing a property;
• Verifying your identity preventing money laundering and detecting fraud or any other criminal activities
• Administrating and protecting our business including its website;
• Identifying you and/or any accounts you hold with us or any purchase you made with us;
• Providing superior customer service;
• Processing transactions through the website to assist in any inquiries;
• Providing transactions history, invoices, receipts, credit notes or any other similar documentation in relation to each client’s purchase;
• Marketing purposes (newsletters, promotions, offers or any other information that may be of interest to you about our new coming projects) 
• Obtaining feedback from you that will help us to improve our services;
• Investigating and responding to any comments, inquiries, complains or requests and deal with any other enquiries, correspondence, concerns or complaints you have raised; and

On what basis do we use your personal information

Personal Data usage by Realty are mainly eliminated to the following provisions:

• to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and auditors;
• to fulfil a deal and proceed with the execution of an agreement;
• to provide you with the requested services prior or after the completion of the project;
• to manage your account;
• to contact you by any mean regarding updates or informative communication related to our new services and/or products;
• with your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes.

How is personal information collected?

We collect your personal information while monitoring our technology tools and services, including comment cards and email communications sent to and from Realty.

Otherwise, we gather information through the following: 

• social media pages such as Facebook, Instagram etc;
• e-mails or enquiries or requests through our website or directly to our company; and
• directly from you for a sale or offer for a specific project.

We may also receive information about you from other sources, such as our business partners, architects, real estate agents, consultants, legal offices, introducers, immigration offices and publicly available sources. We combine information that we have about you from various sources, including the information that you have provided to us.

As part of our comprehensive due diligence procedures, we may use online screening services from reputable software/applications as well as utilize tools that compile information from publicly available sources. We may sometimes gather additional information by conducting internet searches – these can include searches of Registrar of Companies, UK/EU/US sanctions lists, newspapers, law enforcement and any other information which is publicly available. 

Sharing your personal information

Depending on the services rendered from the Group, we may disclose certain of your personal information with the following:

• business partners, architects, consultants, legal offices, immigration offices or third-party service providers of the Group who provide services to us for better serve your needs as a client;
• Analytics and search engine providers that assist the Group in the improvement and optimization of our website;
• Public departments such as Land Registry, Tax Department, Council of Ministers etc.
• our professional advisors and auditors; and
• local or foreign regulators, governments, courts, law enforcement and national security authorities.

We make our utmost efforts third parties to be chosen in a manner consistent with similar principles to ours for the protection of personal data. In any way, we do not allow them to use your personal data for their own purposes unless it is incidental to the services they are providing to you on our request.

Whenever your personal data should be transferred out of EEA, it is our responsibility to ensure a similar degree of protection of the personal data by ensuring that the country involved to this transaction has been deemed to provide an adequate level of protection following the EU Regulations or where appropriate ensuring that they are part of the Privacy Shield (for USA).   

If you have chosen to join a subscription list, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to anyone.

Storage of non-Public Personal Data

We use a variety of security measures and technologies to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction, consistent with applicable data protection and privacy laws. For example, we allow only encrypted communications from all of our web forms, including when you send us an e-mail through our website. We also use the office 365 that is keeping everything encrypted in the Microsoft exchange server.

Realty stores personal information in a secure location and we take steps to ensure that only designated individuals have access to this information.

Retention Time

The duration for which the Group retain your personal data varies and depend on the nature of the services requested as well as our legal obligations for each case. To determine the appropriate retention period, we take into consideration factors such as the quantity, nature and sensitivity of the personal data, the availability of alternative methods to achieve those purposes and any further legal requirements.

Unless you inform us otherwise, any personal data retained by the Group for marketing purposes will be kept until further notification from you.  

Links to other websites

 Our website may include links to websites operated by other firms. Please note that this Privacy Policy exclusively pertains to our website. In addition, if you linked to our website from a third-party site, we cannot be held responsible for the initial operators’ Privacy Policy. We recommend that you review the privacy policy of each third-party operator. 

Changes to This Privacy Policy

We may change, modify or update our Privacy Policy from time to time by posting a new privacy policy on this website. You agree that you will periodically review the updated version found our website in order to make sure that there are no further changes, as they are binding on you.

Users Rights under the GDPR

Every user may exercise certain rights concerning his/her Personal Information. Specifically, Data protection legislation set the following rights to the users:

• Right to be informed
• Rights of access
• Rights to rectification
• Right to erasure
• Right to restrict processing
• Rights to data portability
• Right to object

Realty reserves the right to decline access to your personal information under certain circumstances as permitted by law. 

In addition to the above, if you do not wish to receive marketing information from Realty, you may user the link “unsubscribe” from our electronic marketing communication at any time or you may indicate your wishes by sending us an e-mail to our Data Protection Officer.

Contact US

Any questions/concerns about our Privacy Policy or requests in respect of personal data, please contact directly our Data Protection Officer at dpo@realtymanager.com.cy 

This Privacy Policy was last modified on 16/05/2024