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WHO WE ARE

D. Maratheftis West Coast Ltd are a fully Licensed and Registered Real Estate Agent operating in the territory of Cyprus. We aim to deliver the highest level of service and product available on the market. Our aim is to provide an informative guide for the search for immovable property in the Territory of Cyprus and every reasonable effort shall be made to keep it as an up to date, complete and accurate platform showcasing some of the best real estate properties available on the market in Cyprus.

WHAT WE DO WITH PERSONAL DATA AND WHY WE DO IT

The prime purpose of collecting your data is that it forms a necessary requirement under the Real Estate Act 2010 for the legitimate interests in the marketing and advertising of your property and our obligations under our active sales option agreements. It allows D. Maratheftis West Coast Ltd to communicate effectively and efficiently with all explicitly declared 3rd parties involved (as declared by you in the sales option agreement) in executing a successful sale of your property. Whether D. Maratheftis West Coast are collaborating with lawyers or financial services companies that have been explicitly declared by you or that have been engaged by our clients or offering highly responsive customer support when something goes wrong, our aim is for the sale to complete as effortlessly as possible.

This Privacy Policy (the 'Policy') explains the personal information D. Maratheftis West Coast Ltd collect from you, either directly or indirectly, and how it is used. Personal information is any information that can be used to identify you or that D. Maratheftis West Coast can link to you. The Policy also elaborates on the choices you can make about the data collected, and how you can control these decisions. It applies to all data collected. It also applies to any D, Maratheftis West Coast Ltd controlled websites, as well as other online property portal interactions D. Maratheftis West Coast Ltd may employ or contract to further market your property. Please read this Statement carefully to understand how D. Maratheftis West Coast Ltd may collect, use and share your personal information. The terms 'we', 'us', or 'West Coast' are each intended as reference to D. Maratheftis West Coast Ltd.

The personal data we collect from you / about you is the following:

Personal Data Set

Source of personal data

Name

Voluntarily Provided

Address

Voluntarily Provided

Telephone Numbers

Voluntarily Provided

Email Address

Voluntarily Provided

Title Deeds

Voluntarily Provided

Passport Copies

Voluntarily Provided

Utility Bills

Voluntarily Provided

Previous Contracts of Sale

Voluntarily Provided

Energy Efficiency Certificates

Voluntarily Provided

Company Address’

Voluntarily Provided

Company Inc Documents / Details

Voluntarily Provided

VAT Registration Details

Voluntarily Provided

Date of Birth

Voluntarily Provided

Social Insurance Details

Voluntarily Provided

Location Details

Online Interaction with West Coast Web site

IP Address

Online Interaction with West Coast Web site

We will use your personal data for the following purposes:

  • Advertising & Marketing of our Product

  • Execution of Sales Option Contracts - Direct & Third Party

  • Due Diligence

  • Business Operations

  • Communication & marketing on behalf of Clients

  • Basic Client Administration

  • Customer Support

  • Profiling and Property Matching for Clients

  • Provision of Processing Services to a 3rd Party (but making no decisions that affect

    the individuals)

  • Security, Safety, and Dispute Resolution

  • West Coast controlled Third Party Entities & Associates

  • Compelled Disclosure

  • Sale or Merger

The legal basis on which we process your personal data are the following:

Consent

You may provide us with written consent by way of a signed sales option agreement for the purposes of advertising, marketing and sale or rent of your property. This clearly defines the type of personal information provided along with the supporting documents specifically relating to the sale of your property. This information is given freely and will include a signed and dated agreement. A master copy of the document will be held securely by us and copies of the documents along with copies of the separate privacy policy will be provided to you by one of our controllers.

You may provide us with valid consent. This is consent given freely and may require a positive action to opt in by way of checking a box at the time of making an online enquiry requesting further property details.
Verbal consent may be given feely over the telephone, for which the controller of that information will note the time a date of the consent given verbally. You may be requested to follow up this verbal consent in writing by sending an email to us on info@westcoastcyprus.com. This processing is necessary to serve our legitimate interest. You have the option to opt out of this consent at any time by emailing us at privacy@westcoastcyprus.com or clicking the “unsubscribe” link on promotional emails sent by us. Please be advised that opting out in some circumstances may result in us being unable to fulfil the terms of our contract with you which may negatively affect the sale or marketing of your property. For more information on this please email privacy@westcoastcyprus.com.

Performance of a Contract

The use of your personal information may be necessary to perform the agreement you have with us. For example, for the purposes of acceptance, conclusion and execution of a property sale or purchase or to register and maintain your property preferences.

Legitimate Interest

We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to achieve a property sale for you having been instructed by yourself to market and advertise your property or to acquire your chosen property and secure offers on your behalf. For this purpose, we may be required to share some of your personal details. We also rely on legitimate interest to analyse and improve our West Coast Products and Services and the content on our websites, to send you notifications about West Coast Products and Services, you may have requested information on a property or similar properties, therefore it is in our legitimate interest to respond to your requests or to use your personal information for administrative, fraud detection or legal purposes.

Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you may exercise your right to opt out by sending an email to privacy@westcoastcyprus.com.

The legitimate interests pursued by us, or third parties, are as follows:

  • Registration of Property Viewings (As required by Real Estate Act 2010)

  • Successful completion of a Property Sale

  • Acquisition of Property Sale

  • Analysis & Improvement of West Coast Product

  • Analysis & Improvement of West Coast Services

  • Response to Property Enquiry

  • Administrative Purposes

  • Fraud Detection

  • Legal Purposes

  • Banking Compliance Regulations

    Special categories of data are the following:

    D. Maratheftis West Coast Ltd does not collect Special Categories of Data.

YOUR CONSENT

When you give your consent to this privacy notice, this means that we can process your personal data for the purposes identified in this privacy notice.

You may withdraw consent at any time by emailing us on privacy@westcoastcyprus.com.

DISCLOSURE OF YOUR PERSONAL DATA

D. Maratheftis West Coast Ltd may disclose your personal data to the following third parties

D. Maratheftis West Coast Ltd Controlled Affiliates & Associates.
Property Vendors for the purpose of registering property viewings.
Legal Entities Elected by yourself for the purpose of completion of a property sale. Banking Institutions for the purpose of compliance regulations.

Third Country Disclosure

The only occasion D. Maratheftis West Coast Ltd may share your personal information with a third country would be for the specific purpose of registering a property viewing with a specific individual that originates from the third country.
Disclosure will be done so securely through email with end to end secure encryption.

HOW LONG WE KEEP YOUR DATA FOR

D. Maratheftis West Coast Ltd will process your data and will store your data for as long as we deem it necessary to enable you to achieve a successful sale or rental, to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Privacy Statement and our internal retention guidelines. This duration has been established on the basis of our contractual obligations and in accordance with financial regulations.

YOUR RIGHTS

As a data subject you have a number of rights under law. These are the following:

Right of access – you have the right to request a copy of the information that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

Right of portability – you have the right to have the data we hold about you transferred to another organisation.

Right to object – you have the right to object to certain types of processing such as direct marketing. 

Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain to the appropriate authorities about this.

You can request access your data by accessing the following link: privacy@westcoastcyprus.com

COMPLAINTS

In the event that you wish to make a complaint about how your personal data is being processed by us, we recommend that you first lodge your complaint with our Data Protection Officer at privacy@westcoastcyprus.com. If you remain unsatisfied, you may pursue your complaint further by lodging a complaint with the following authority:

PRIVACY STATEMENT

Website Privacy policy

1. Introduction

1.1  We are committed to safeguarding the privacy of our website visitors and users. In this policy we explain how we will handle your personal data.

1.2  By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.3  This website is owned and operated by D. Maratheftis West Coast Ltd. 

1.4  You can contact us at privacy@westcoastcyprus.com.

1.5  Our data protection officer contact details are: privacy@westcoastcyprus.com.

2. How we use your personal data

2.1  We may process [data about your use of our website and services] ("usage data"). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is [our analytics tracking system]. This usage data may be processed [for the purposes of analysing the use of the website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [monitoring and improving our website and services]] OR [[specify basis]].

2.2  We may process [your account data] ("account data").[ The account data may [include your name and email address].][ The source of the account data is [you]. The account data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.] The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

2.3  We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, date of birth, relationship status, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is [consent] OR [our legitimate interests], namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

2.4  We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, email address or contact telephone number. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is [consent] OR [our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.5  We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is [consent] OR [our legitimate interests, namely the proper administration of our website and business OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

2.6  We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is [consent] OR [legitimate interest].

2.7  We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your banking details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.8  We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is [consent] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. You may unsubscribe from this communication at anytime by clicking the “unsubscribe from this email” notification at the bottom of the email, although this may jeopardize our ability to fulfil the performance of our contract or your request. We rely on you to ensure that your personal information is complete, accurate and up to date.

Please do inform us promptly of any changes to or inaccuracies in your personal information by contacting privacy@westcoastcyprus.com. 

2.9  We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.10  we may also process [any of your personal data] where such processing is necessary [for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.

3. Disclosure of Personal Data

In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation, in order to protect your vital interests or the vital interests of another natural person.

4. International transfers of your personal data

The only occasion D. Maratheftis West Coast Ltd may share your personal information with a third country would be for the specific purpose of registering a property viewing with a specific individual that originates from the third country.
Disclosure will be done so securely through email with end to end secure encryption.

5.Retaining and deleting personal data

5.1  Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.2  In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of (“notification & correspondence data”) will be determined or based on the time taken to achieve a successful sale or rental, to provide services to you, to comply with applicable laws (including those regarding

document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business.

5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1  We may update this policy from time to time by publishing a new version on our website.

6.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

7. Your rights

7.1 In terms of data protection legislation, you have the followings rights:

(a)  the right to access;

This means that you have the right to ask us whether or not we process your data and if we do access to the personal data, together with certain additional information, i.e. the details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. This will be provided to you free of charge.

(b)  the right to rectification;

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

(c)  the right to erasure;

In some circumstances you have the right to the erasure of your personal data without undue delay.

(d)  the right to restrict processing;

In some circumstances you have the right to restrict the processing of your personal data.

(e) the right to object to processing;

In some circumstances you have the right to object to processing of your personal data.

(f)  the right to data portability;

In some circumstances you have the right to request a portable copy of your personal data.

(g)  the right to complain to a supervisory authority; and

You have the right to submit a complaint with a supervisory authority responsible for data protection.

(h)  the right to withdraw consent.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8. About cookies 

8.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 

8.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

9.1 We use cookies for the following purposes:

We use cookies and other similar technologies like pixels, tags and web beacons when you visit our website. By visiting our website, you agree to the use of cookies and similar technologies for the purposes described in our privacy policy. This helps us to provide you with the best experience and allows certain parts of our website to function properly.

10. Cookies used by our service providers

10.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 

10.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy.

10.3  To help more people find your property and West Coast, we use several modern marketing tools in support of our advertising efforts.
West Coast may work with third-party advertisers that use cookies and similar technologies to provide more relevant advertising about West Coast Properties and Services on our websites and across the internet. To provide this “interest-based advertising”, parties combine non-personal data about your online activities over time which helps cater advertising that we deliver to you. Examples of this may include a West Coast advertisement on a Facebook page, or a Google owned page such as a search results page or YouTube, or on a site within Google’s advertising network. We do not share your personal information as part of this process. If you have opted out of receiving communications from us, we will not use your email for interest-based advertising.

11. Managing cookies

11.1  You can always adjust your browser or device settings to not accept cookies and similar technologies if this concerns you.

11.2  Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impair your overall user experience, as it will no longer be personalised to you. Some browsers offer a “Do Not Track” (“DNT”) signal where you can indicate your preference regarding tracking and cross-site tracking. Although we do not currently employ technology that recognises DNT signals, we will only process your personal data in accordance with this Policy.