Политика конфиденциальности

REINVEST (“REINVEST”) respect your privacy and are committed to protecting your personal data, as well as in general protecting all information collected. This privacy notice and any other notice referred to in it, explains how we collect your personal data and how we use it when you visit our website, in accordance with GDPR requirements.

We are a data controller in respect of the personal data we collect and process when you visit our website. We are not legally obligated to appoint a Data Protection Officer; however, if you have any questions or concerns in relation to this Privacy Notice please contact REINVEST at info@reinvest.com.cy or write to Reinvest APM Ltd at Kyriakou Matsi 11, 7th Floor Nikis Centre, 1082 Nicosia, Cyprus.

We do not share your information with third parties.

This website is not intended for children.

This Privacy Notice was last updated in February 2019. It supersedes any earlier version. We may update it from time to time, in which case we will notify you of any significant changes through a notice on our website.

Third-party links

This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their use of your personal data.

1. WHAT INFORMATION WE MAY COLLECT AND HOW WE USE IT

As a business we collect, use, store and transfer different types of personal data depending on who you are.

If you are purchasing, renting, selling or letting a property through us, or purchasing, renting, selling or letting a property from one of our clients, we collect and use your personal data in order for us to provide you with our services. The personal data we collect and use may include but are not limited to:

  • Identity Data (name, marital status, title, date of birth, gender, I.D. no., passport no., username and password, purchases made by you, your interests and preferences, feedback and survey responses, company name, company registration no.)
  • Contact Data (billing address, delivery address, email address and telephone numbers)
  • Financial Data (bank account and payment details)
  • Transaction Data (details about payments to and from you and other services you have purchased through us)
  • Technical Data (internet protocol address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, online identified, location data and other similar identifying information required for the customer’s device(s) to communicate with websites and applications on the internet)
  • Usage Data (how you use our website products and services, the full uniform resource locators clickstream to, through and from our site (including date and time), download errors, lengths of visit to certain pages, page interaction information, methods to browse away from the page and any phone numbers you use to call us)
  • Marketing and Communications Data (your marketing preferences from us and your communication preferences)

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can ask us to rectify or update your personal information at any time by email to info@reinvest.com.cy or by writing to Reinvest APM Ltd at Kyriakou Matsi 11, 7th Floor Nikis Centre, 1082 Nicosia, Cyprus.

2. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide:

  • When you apply for our services; If you create an account on our website;
  • When you subscribe to our service or publications;
  • When you request marketing to be sent to you;
  • If you contact us through social media;
  • When you walk-in to our branch offices or telephone our call centre; or
  • If you give us some feedback.

3. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data for the legitimate purposes for which we have collected it. If we need to process your personal data for a different purpose that is not compatible with the original purpose that we collected your personal data, we will let you know.

We may process your personal data for a different purpose and without your consent where it is necessary for us to comply with our legal obligations.

Purpose / Activity Legal basis for processing Type of Data required
To contact you

Performance of a contract with you

Necessary for our legitimate interests (for running our business, to recover debts due to us, to keep our records updated and to study how customers use our products/services)

1) Identity Data

2) Contact Data

3) Financial Data

4) Transaction Data

5) Marketing and Communications Data

To carry out our obligations arising from any contracts entered into between you and us and to provide you the information, products and services you request from us

Performance of a contract with you

Necessary for our legitimate interests (for running our business and to recover debts due to us)

1) Identity Data

2) Contact Data

3) Financial Data

4) Transaction Data

5) Marketing and Communications Data

To provide you with information about other goods and services that we offer which we feel may be of interest you Necessary for our legitimate interests (to develop our products/services and grow our business)

1) Identity Data

2) Contact Data

3) Technical Data

4) Usage Data

To assist us in the improvement and optimisation of advertising, marketing material and content, our services and the website Necessary for our legitimate interests (to develop our products/services and grow our business and provision of administration and IT services)

1) Identity Data

2) Contact Data

3) Financial Data

4) Transaction Data

5) Marketing and Communications Data

To notify you about changes to our service

Performance of a contract with you

Necessary to comply with our legal obligations

Necessary for our legitimate interests (to keep our records updated)

1) Identity Data

2) Contact Data

To ensure that content from our website is presented in the most effective manner for you and your computer Necessary for our legitimate interests (to develop our products/services and grow our business and provision of administration and IT services)

1) Identity Data

2) Contact Data

3) Financial Data

4) Transaction Data

To verify your identity

Necessary to comply with our legal obligations

Necessary for our legitimate interests (for running our business and to prevent fraud and money laundering)

1) Identity Data

2) Contact Data

3) Financial Data

4) Transaction Data

As part of our efforts to keep our site safe and secure and to prevent or detect fraud

Necessary to comply with our legal obligations

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

1) Identity Data

2) Contact Data

3) Financial Data

4) Transaction Data

To provide customer support Performance of a contract with you

1) Identity Data

2) Contact Data

To facilitate and to enable you to partake in a property viewing, open house event or visits to property marketing suites

Performance of a contract with you

Necessary for our legitimate interests (for running our business and to develop and grow our business)

1) Identity Data

2) Contact Data

To comply with the requirements imposed by law or any court order Necessary to comply with our legal obligations

1) Identity Data

2) Contact Data

3) Technical Data

4) Usage Data

Where you have viewed through us, we may disclose your name to a landlord or vendor where we have been dis-instructed, in order to avoid a potential commission dispute Necessary for our legitimate interests (to protect our entitlement to a commission and to avoid commission disputes wherever possible) 1) Your name

Marketing

You have the right to withdraw your consent for us to use your personal data for marketing purposes at any time. If you do withdraw your consent, this will result in us ceasing to market goods and services to you.

Should we send any marketing messages to you, you can ask us to stop sending you these at any time by:

  • Following the opt-out links on any marketing message sent to you;
  • If you have been given the option to open an ‘REINVEST account’ by logging into your ‘REINVEST’ account and checking or unchecking relevant boxes to adjust your marketing preferences or
  • Contacting us at any time by emailing info@reinvest.com.cy or by calling 7778 7771.

If you do withdraw your consent to receiving marketing messages, we will still process your personal data in order to fulfil our contract with you and in accordance with our legal, accountancy and regulatory obligations.

4. DISCLOSURES OF YOUR PERSONAL DATA

In the future, we may have to share your personal data with the parties set out below for the purposes set out in “How we use your personal data”. Should we do so, we will ensure that we have agreements in place that restrict these parties’ use of your personal data. We will only allow them to use your personal data for specified purposes and in accordance with our instructions.

  • Service providers acting as processors based in the EU/EEA who provide IT and system administration services, tenancy deposit administrators and services to enable us to perform our contract with you.
  • Property developers acting as Processors or independent controllers based in Cyprus who process your personal data in order to arrange and facilitate your visit to their marketing suite.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Cyprus who provide consultancy, banking, legal, insurance and accountancy services.
  • Government entities, regulators and other authorities acting as processors or joint controllers based in Cyprus who require reporting of processing activities in certain circumstances.

Anti-Money Laundering

REINVEST is registered and supervised by the Real Estate Association in Cyprus for compliance with the Prevention & Suppression of Money Laundering Activities Law of 2007, N.188(I)/2007. We are committed to operating our business in a transparent and open manner consistent with our legal and regulatory obligations. We are aware that the real estate industry is a target for organised criminals seeking to launder the proceeds of criminal activity. We always seek to prevent this activity by cooperating fully with the authorities and reporting suspicious activity to the Unit for Combating Money Laundering (MOKAS). As part of this commitment, we adopt a strict compliance of all Anti-Money Laundering rules currently in effect.

REINVEST policy commitment is applicable to all of our customers, including vendors, buyers, landlords and tenants. As a result we obtain and hold for a period of at least seven years evidence pertaining to our customers’ identity and, where appropriate, we obtain proof of ownership of property and source/destination of funds. We will be unable to proceed with any work on behalf of our customers if we are unable to obtain this information. Customers’ identity will be subject to an electronic identity check, which may also include a credit check.

5. DATA SECURITY

Once we have received your personal data we will use reasonable and necessary procedures and security features to try and prevent unauthorised access. We limit access your personal data to those individuals and other parties who need to know it and who are subject to a duty of confidentiality. If we become aware of a data breach we will notify the Office of the Commissioner for personal data protection. If we believe that the data breach is serious, we may notify you in accordance with our legal requirements. We have an Internal Data Breach Policy in place that lays out our responsibilities and procedures.

6. INTERNATIONAL TRANSFERS

We will not transfer your personal data outside of the European Economic Area, except to a country offering the same level of protection for your personal data, and only according to GDPR requirements.

7. DATA RETENTION

We hold on to your personal data whilst you use our services (or whilst we provide services connected to you) and for at least seven years thereafter, for legal, regulatory and accounting purposes. If we need to hold on to your personal data for longer, we take into consideration the potential risks in continuing to store your data against why we might need to keep it. In some circumstances we might anonymise your personal data so it is not associated with you, and we may then use this information indefinitely.

8. YOUR LEGAL RIGHTS

Under data protection laws you have the right to protect and look after your personal data. You have the right to:

  • ask us for the personal data that we hold and process about you (this is commonly known as a data subject access request). You have rights to the following information:
    • the purpose(s) for which we are processing your information;
    • the categories of personal information we hold about you
    • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
    • the period for which we will store your information, or the criteria used to determine that period;
  • prevent the use of your personal data for marketing purposes
    • Please note that even if you refuse marketing, we will contact you to discuss the services you have asked us to provide to you or to tell you about changes to our terms and conditions;
  • ask that any inaccurate information we hold about you is corrected;
  • ask that we delete the personal data we hold about you in certain situations;
  • ask that we stop using your personal data for certain purposes;
  • ask that we do not make decisions about you using completely automated means; and/or
  • ask that personal data we hold about you is given to you, or where technically feasible a third party chosen by you, in a commonly used, machine-readable format.

The rights listed above may not apply in certain circumstances, and so we may not always be able to comply with your request to exercise these rights. We will usually respond to a request from you to exercise your rights within 1 month of receipt, but it might take longer if your request is particularly complex or if you have made a number of requests. Please be aware that we may need to process your personal data and/or request specific information from you to help us comply with your request. You will not usually have to pay a fee to exercise these rights, but we reserve the right to if your request is clearly unfounded, repetitive or excessive, alternatively we may refuse to comply with your request.

Complaints and Feedback

If you would like to speak to us about how we handle your personal data, we would be grateful if would please contact us in the first instance at info@reinvest.com.cy You can also complain to the Cyprus supervisory authority for data protection issues.

REINVEST consists of the following corporate structures:

  • REINVEST APM LTD
  • REINVEST AGY LTD

Registered in Cyprus under HE387086 and HE387083 respectively. Our registered office is at 2 Dramas Street, 4th Floor, P.C. 1077 Nicosia, Cyprus.

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