It was implemented from 16/04/2022
Dear customer, we would like to inform you about the company «ROBURA LIMITED (HE 394618)» (hereby referred as the «Company»), the protection of our customers' personal data is of primary importance. Therefore, we take the appropriate organizational and technical measures to protect the personal data we process and ensure that personal data is always processed in accordance with the obligations set by the legal framework both by the Company itself and by third parties who process personal data on behalf of the Company.
The main activity of the Company is, inter alia, the provision of management services of all types of properties/real estate management located in Cyprus and abroad through advertisements posted on the Website "theprosperty.com.cy" whose sole official beneficiary and administrator throughout the Republic of Cyprus is the Company or on any other website the Company may choose.
What is GDPR?
The General Data Protection Regulation (GDPR) 2016/679 constitutes the new regulatory framework of the European Union (EU) in the field in question. The object of the law is to establish the conditions for the processing of personal data in order to protect the rights and freedoms of individuals and in particular the right to protection of personal data.
What is personal data?
It is any information that relates to an individual who can be directly or indirectly identified («data subject»)· an identifiable individual is the one whose identity can be verified, directly or indirectly, in particular by reference to an identity identifier, such as name, identity number, location data, online identifieror to one or more identifying factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
Processing of Personal Data
Any processing act or series of processing acts carried out with or without the use of automated means in personal data or in personal data sets, such as the collection, registration, organization, structure, storage, adaptation or alteration, retrieval, search for information, use, disclosure, dissemination or any other form of distribution, association or combination, restriction, deletion or destruction.
Data Controller
The Company, with registered office in Ledras 192, 3rd Floor, 1011, Nicosia, Cyprus, email: info@theprosperty.com.cy, tel. (+357) 22848320, website: www.theprosperty.com.cy.as legally represented, informs that, for the purposes of conducting its businesses activities, it processes personal data of its clients in accordance with the applicable national legislation and the European Regulation 2016/679 for the protection of individuals against the processing of personal data and for the free circulation of such data (General Regulation on Data Protection, herein after referred to as "the Regulation") as in force.
For any issue regarding the processing of personal data you can contact the Department of Personal Data Protection and the Data Protection Officer (DPO) of Company at the following contact details:
Email: gdpr@ekllc.eu
Telephone: (+357) 22676752
What are the legal reasons for processing your personal data?
Legitimate reasons for processing your personal data are:
The management by the Company of your properties located in Cyprus and/or abroad which are included in the Website “theprosperty.com.cy” of the Company etc and consequently the fulfillment of our contractual obligations in this context.
regulatory compliance for tax purposes.
the consent you provide under the specific conditions set by the legal framework, in order to receive updates on products, services, offers, where personal data are processed in accordance with the applicable framework.
STATEMENT
You declare responsibly by giving your consent that you are over 18 years old. If you are under 18 years old, you may use our website only with the participation and approval of a parent or guardian.
How and why do we use your personal data?
Creation of Account
Personal data is collected when you create an account at www.theprosperty.com.cy , managed by Company. When creating an account you may be asked for more details, however the minimum required to enter into and execute the contract will be marked as required.
Account registration: The following personal information are mandatory: Name, Address, Postal Code, Region, City, Country, Telephone and Email Address. Next, you will need to set a password by typing it twice. To complete your registration, you must, after reading the terms of use, select the box in the "I agree" option and fill in the text to verify your registration.
Your registration will be complete. The username is now your email address and the password is your personal password.
You must not disclose your personal password to third parties, nor keep it in electronic or printed form, to prevent any unauthorized use. In case of disclosure of your codes to a third party, you have the obligation to immediately inform Company.
In the event of a data leak, Company has no responsibility as long as it has not been previously informed about the illegal use of this data.
By creating an account, you can always edit your data, either add or remove items. This information will be used to make the process of completing your order easier every time you visit our website, if you choose to be logged in.
Rental – Subrental execution
Personal data is collected when you conclude a rental or/and subrental agreement to our Web Page. To complete your rent or/and sublet, either as a logged in user or as a visitor, you will be asked to enter additional details, however they will be the minimum for the conclusion and execution of your request. These details are marked as required fields. The information already in your account, once logged in, will be used to complete the rental or subrental agreement, along with some additional information you will need to enter, such as payment method information, different shipping address (optional), details for the issuance of an invoice, profession, brand, where necessary.
During the process of completing your request, some of this data is transmitted to partner companies. Data is provided to transport companies for the transportation and delivery of your products and/or services. Transport companies can contact you to ask for clarifications and / or provide you with further information on the delivery of your products. In addition, the data is transmitted when making a payment to payment providers (banks, PayPal).
Our Company uses high security systems to prevent data leakage from malicious systems.
Sending information and promotional material / Company news
When you visit our website www.theprosperty.com.cy you can fill out a contact form by entering your email address in order to subscribe to our Newsletter.
The data collected from our website may be used to contact you via email for promotional / advertising purposes, in order to inform you about products and/or services and/or offers that may be of interest to you, provided that you have given your consent, under the specific conditions setting the legal framework.
Information posted on the internet in search engines and social media (Google, LinkedIn, Facebook, Twitter, Instagram) may be processed by us, in the context of Company’s legitimate interest in generating market interest in its products and/or services, in order to create a more personalized promotion and information of potential customers by phone and / or email for the above commercial purpose. The legal basis is the voluntary publication of your information in search engines and your registration in social media services, where you give explicit consent to the publication of information depending on the settings of the applications that you manage.
Legal bases for the above processing are both the execution of our contractual obligations (EU GDPR article 6 par. 1b “Lawfulness of processing”), and the legal interest of our Company (GCP article 6 par. 1f).
Personalized information
Always aiming to offer the best possible experience to our customers, the personal data collected from our website may be used to send personalized / personalized updates, provided you have given your consent, subject to the specific conditions set by the legal framework. Personalization, which is based on your needs and preferences, comes from the data we draw from your personal data, such as profession, area of residence, etc., or from the purchases you make.
Profile creation
Profiling refers to any form of processing of personal data in an automated manner, which consists in the use of personal data for the evaluation of certain personal aspects of a natural person, with the main purpose of analyzing or predicting aspects related to personal preferences and interests of the natural person.
We inform you that a profile is created for marketing purposes, when you give your consent to receive updates regarding our products and offers, personalized to your personal preferences and interests.
Where is your data published?
The Company transmits the personal data given by individuals to third companies, which offer automation services for the purpose of sending mass of electronic messages.
In addition, to complete a rental or/and subrental some of this data is transmitted to partner companies, e.g. to the real estate company PROPERTYPINS REAL ESTATE LTD with registration number HE 400656 and/or other real estate companies with whom the Company cooperates, who may contact you for clarifications and/or information on the delivery of your products and/or services.
Also, this data is accessible to companies of information support systems and marketing of our Website, where the Company ensures the protection of this data with strict terms of confidentiality and continuous control of the organizational measures taken by these companies.
Finally, the data is transferred during payment execution to payment providers. Our Company uses high security systems to prevent data leakage from malicious systems.
Storage Period of personal data
With regard to the data storage period, this is decided taking into account the following specific criteria as appropriate:
When processing is required by the provisions of the applicable legal framework, your personal data will be stored for as long as the relevant provisions require.
When processing under contract, your personal data is stored for as long as is required to execute the contract and to establish, exercise, and/or support legal claims under the contract.
In the case of marketing activities, your personal information is kept until your consent is revoked. This can be done by you at any time. Revocation of your consent does not affect the legality of the processing based on your consent during the period prior to its revocation.
To revoke your consent you can contact Company’s Personal Data Protection (DPO) Department at the following contact details: email: info@theprosperty.com.cy.In case you want to contact the Data Protection Officer (DPO): Anastasia Papamichael, phone: (+357) 22676752
You can also use the unsubscribe options by clicking on the corresponding link that exists in our electronic communications.
Personal Data Security
The Company implements appropriate technical and organizational measures aimed at the secure processing of personal data and the prevention of accidental loss or destruction and unauthorized and/or illegal access to them, their use, modification or disclosure. However, the way the internet operates and as it is free to anyone, we cannot guarantee that unauthorized third parties will never be able to violate the applicable technical and organizational measures by gaining access to and possibly using personal data for unauthorized and/or illegal purposes.
Your rights in relation to your personal data:
Right of access:
You have the right to be aware and to verify the legality of the processing. Thus, you have the right to access the data and receive additional information about their processing.
Right of correction:
You have the right to study, correct, update or modify your personal data.
Right to delete:
You have the right to request the deletion of your personal data when we process it with your consent or in order to protect our legal interests. In all other cases (such as when there is a contract, the obligation to process personal data imposed by law, public interest), this right is subject to certain restrictions or does not exist as the case may be.
Right to restrict processing:
You have the right to request a restriction on the processing of your personal data in the following cases:(a) when you dispute the accuracy of the personal data and until it is verified, (b) when you oppose the deletion of personal data and request instead of the deletion the restriction of their use, (c) when personal data are not needed for processing purposes, however you are necessary to establish, exercise, support legal claims, and (d) when you object to the processing and until verification that there are legitimate reasons for us override the reasons why you oppose editing.
Right to object to processing:
You have the right to object at any time to the processing of your personal data in cases where, as described above, it is necessary for the purposes of the legitimate interests we pursue as controllers, as well as to the processing for the purposes of direct marketing and consumer profiling.
Right to portability:
You have the right to receive your personal data free of charge in a format that allows you to access, use and process it using commonly used processing methods. You also have the right to request that, if technically possible, we transfer the data directly to another controller. This right exists for the data that you have provided to us and their processing is carried out by automated means based on your consent or in execution of a relevant contract.
Right to withdraw consent:
The Company informs you that where processing is based on your consent, you have the right to revoke it freely, without prejudice to the legality of the processing based on your consent, before revoking it.To revoke your consent you can use the unsubscribe options, by clicking on the corresponding link that exists in our electronic communications or by contacting the electronic address: gdpr@ekllc.eu
To exercise any of the above rights you can contact the Personal Data Protection Department (DPO) of the Company, at the following contact details: email: info@theprosperty.com.cy. In case you want to contact the Data Protection Officer (DPO) Anastasia Papamichael, email: gdpr@ekllc.eu, phone: (+357) 22676752
Right of complaint to the Authorities
You have the right to file a complaint with the Personal Data Protection Authority at the following link: