How we respect privacy when we deal with personal information collected by our organisation.
1. Personal data that we process
|Purpose||Data (key elements)||Basis|
|Enquiring about our organization and its work||Name, email, telephone number, message||Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect.|
|Enquiring about one of our properties available for Rent of Sale||Name, email, telephone number, message||Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect.|
|Subscribing to email updates about our work||Name, email||Consent – you have given your active consent.|
|Arranging a viewing for one of our properties||Name, email, telephone number, address, home, family and lifestyle information.||Legitimate interests – this information is necessary for us to fulfil your intention to view a property that interests you from our organization, to do so, Your contact information is needed to fulfill your expectation of receiving a confirmation message, and a successful or unsuccessful reply to your viewing request.|
|Signing a rental, sales or property management agreement||Name, email, address, Identification Document or passport information.||Contract – Your information is needed to prepare a contract, terms and conditions depending on the actual deal and the party's interests.|
|Signing a property viewing form||Name, email, address, Identification Document or passport information.||Legitimate interests – this information is necessary for us to inform the owner of the property that you have viewed his property.|
|Signing a listing agreement||Name, email, address, Identification Document or passport information.||Legitimate interests – this information is necessary as you will be giving instructions to either sell or rent your property.|
|Signing offer form||Name, email, address, payment information||Contract – this information is necessary to make a written offer to the owner of the property|
|Website functionality||Website activity collected through cookies||Legitimate interests – it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of your order before you have fully completed the process.|
2. How we use your data
We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this policy.
For example, we may use your personal information to:
- reply to inquiries you send to us;
- assessing and ranking the application and responding to an application for viewing a property
- handle other transactions that you initiate;
- where you have specifically agreed to this, send you marketing communications by email relating to our work that we think may be of interest to you.
3. When we share your data
We will only pass your data to third parties in the following circumstances:
- you have provided your explicit consent for us to pass data to a named third party;
- we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfills our legal obligations in relation to the use of third-party data processors; or
- we are required by law to share your data.
In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation.
4. How long we keep your data
We take the principles of data minimization and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.
Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.
5. Rights you have over your data
You have a range of rights over your data, which include the following:
- Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting 'unsubscribe' links at the bottom of all our marketing emails).
- You have the right to ask for rectification and/or deletion of your information.
- You have the right of access to your information.
- You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.
A full summary of your legal rights over your data can be found on the Information Commissioner's website here: https://ico.org.uk/ The European Data Protection Board website here: https://edpb.europa.eu/ and the Cyprus office of the commissioner for personal data protection here: http://www.dataprotection.gov.cy/
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us. Please note that relying on some of these rights, such as the right to delete your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.
6. Cookies & usage tracking
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.