Our Terms

Privacy Policy

TANDY CHRISTOFOROU REALTY LTD – Privacy Policy

This Data Protection Privacy Policy shall be effective as and from the 23rd October 2024.

This Privacy Policy constitutes the guide according to which TANDYREALTY manages personal data and outlines the approach of TANDYREALTY under the General Data Protection Regulation 2018 (GDPR). In this guide it is explained how TANDYREALTY  collects personal information about the Users, how TANDYREALTY uses it and how the Users can interact with TANDYREALTY about it.

1. DEFINITIONS

  1. 1.1.Applicable Law shall mean laws and regulations of the Republic of Cyprus and the GDPR.
  2. 1.2.Business Day shall mean a day other than Saturday, Sunday or a public holiday, when Banks in Cyprus are open for business.
  3. 1.3.Calendar Month shall mean 30 (thirty) consecutive calendar days.
  4. 1.4.Cyprus shall mean the Republic of Cyprus.
  5. 1.5.Data shall mean the User’s or any Third Party’s name, ID number and details, Passport number and details, date of birth, Inland Revenue Number or any foreign equivalent, phone numbers, telefax numbers, email address, IP address, online user identifiers, cookie identifiers, CCTV images and include and Sensitive Data.
  6. 1.6.TANDYREALTY shall mean TANDY CHRISTOFOROU REALTY LTD.
  7. 1.7.GDPR shall mean the General Protection Regulation 2018.
  8. 1.8.Guide shall mean this Data Protection Privacy Policy.
  9. 1.9.Sensitive Data shall mean sensitive personal information about a User such as political, social, religious or ethical beliefs or affiliations, colour, race, ethnic or national origins, and sexual preferences or practices.
  10. 1.10.Third Party shall mean any person, individual or corporate, except TANDYREALTY, the Vendor and the User.
  11. 1.11.User or Users shall mean each one user separately and all the users collectively of the Website.
  12. 1.12.Vendor or Vendors shall mean the vendor of the Property.
  13. 1.13.Website shall mean www.TandyRealty.com.cy and all subdomains.

 

2. REASONS FOR COLLECTION OF INFORMATION BY TANDYREALTY AND TYPE OF INFORMATION

There are a number of reasons why TANDYREALTY collects information, such as to know how to contact the User, to be certain of User’s identity and to understand User’s circumstances so that TandyRealty can offer the user the best possible customer experience.

The type of information that TANDYREALTY may collect from Users includes:

  • User’s identity & contact name, copies of ID (which may include the date of birth), I.R. number (or foreign equivalent), online user identifiers (such as login details), IP addresses, cookie identifiers, email addresses and contact phone numbers.
  • Bank account details, credit/debit card details, authorized signatory details, information relating to power of attorney arrangements.
  • Sensitive categories of Data – TANDYREALTY  may hold information about User which includes sensitive Data. TANDYREALTY only holds this Data when it needs to for purposes of the service it provides to Users or where TANDYREALTY has a legal obligation to do so. TANDYREALTY is required to process sensitive Data when it seeks his/her ID or passport in order to comply with its anti-money laundering obligations.
  • The information which the User has consented to TANDYREALTY using such as allowing TANDYREALTY to contact and send the User property related communications on a periodic basis. TANDYREALTY  also collects information about User’s internet activity using the technology known as cookies which can often be controlled through internet browsers. A cookie is a little piece of text that TANDYREALTY ’s server places on User’s device when he/she visits the Website. A cookie helps TANDYREALTY to make the Website work better for the Users.
  • TANDYREALTY  uses technologies to automatically collect information about User’s internet browser settings or Internet Protocol (IP) address, login information, location-based data and google analytics to improve its Website offering to Users and to enhance User’s online visit to TANDYREALTY .
  • TANDYREALTY may also collect CCTV images at its office locations (but only for security reasons and to help prevent fraud or crime). TANDYREALTY will also hold information on data access, correction, restriction, deletion, porting and complaints relating to the Users.

 

3. HOW TANDYREALTY COLLECTS INFORMATION ABOUT THE USER’S AND WHEN?

TANDYREALTY  collects information about Users in a number of ways, included but not limited to:

  • When User makes a request to be added to TANDYREALTY ’s marketing database.
  • When User uses TANDYREALTY ’s Website.
  • When User or others give TANDYREALTY information verbally or in writing. This information may be by way of registration forms, viewing attendee sheets, through correspondence with TANDYREALTY  or if the User makes a complaint.
  • From User’s online activities with third-parties where User has given TANDYREALTY  his/her consent (e.g. by consenting to TANDYREALTY ’s use of certain cookies or other location tracking technologies).

 

4. USE OF DATA BY TANDYREALTY

TANDYREALTY  may use User’s Personal Data for matters such as confirming his/her identity in order to enable TANDYREALTY  in the processing of an application for one of TANDYREALTY ’s services or to improve the User’s customer experience with TANDYREALTY .

Data is used to manage and administer User’s account. Personal Data is also used to process transactions.

TANDYREALTY  may use User’s Personal Data to contact him/her by post, phone, text message, email or social media using the Website or other means but not in a way that is contrary to User’s instructions to TANDYREALTY, legitimate interest or contrary to the Applicable Law. TANDYREALTY  may monitor and record its conversations when it speaks on the telephone (to verify the User’s instructions to it and for training and quality purposes) by advising the User accordingly. Personal Data may also be used to recover debts the User’s may owe and to manage and respond to a complaint the User may have.

TANDYREALTY  may also use Personal Data to manage its business for its legitimate interests, such as gathering location information from User’s mobile phone or another electronic device the User may use to interact with TANDYREALTY. Another legitimate interest of TANDYREALTY is to conduct marketing activities such as direct marketing and research, including customer surveys, analytics, and related activities.

Personal Data may be used to carry out strategic planning and business portfolio management. This could include compiling and processing User’s information for audit, statistical or research purposes (including, making the User’s Data anonymous) to help TANDYREALTY understand trends in its customer behaviour and to understand its risks better, including providing management information, operational and data risk management.

TANDYREALTY  may use User’s Data to protect its business, reputation, resources and equipment, to manage network and information security (developing, testing and auditing the Websites and other TANDYREALTY ’s systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted Data, and the security of the related services).

TANDYREALTY  protects User’s information with security measures under Applicable Law, and TANDYREALTY  meets international standards in doing so. TANDYREALTY  keeps its equipment, files, and buildings secure. Data could be used to prevent and detect fraud, dishonesty and other crimes (such as preventing someone from trying to steal User’s identity), including using CCTV at TANDYREALTY office premises.

TANDYREALTY may in the future wish to sell, transfer or merge part or all of its business or assets or to buy a new business or the assets, of another business or enter into a merger with another business. If so, TANDYREALTY may disclose User’s Data under strict duties of confidentiality to a potential buyer, transferee, merger partner or seller and their advisers, so long as they agree to keep it confidential and to use it only to consider the possible transaction.

TANDYREALTY needs to use User’s Data to manage and administer legal and compliance matters within TANDYREALTY , including compliance with regulatory, legislative and voluntary codes of practice to which TANDYREALTY has committed. TANDYREALTY  uses its data to comply with User’s information rights, to establish User’s identity and to comply with laws and regulations concerning the prevention of money laundering, fraud, and terrorist financing. As a result, TANDYREALTY  may need to disclose information to the government and other statutory bodies. User’s Data may be used to comply with binding court orders, search warrants, requests to assist the Police Authorities with the investigation or prevention of an offence and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies.

 

5. USE OF AUTOMATED PROCESSING OR ANALYTICS

TANDYREALTY  does not use automated processing in relation to the information it collects from the User’s as part of its business.

TANDYREALTY  uses analytics only for statistical purposes in order to be able to make more informed business decisions, including improving the quality of services it can offer.

 

6. SHARING OF INFORMATION WITH THIRD PARTIES

TANDYREALTY  only shares the User’s information with a certain number of other parties and only as necessary in particular cases, some examples of which are the following:

  • User’s authorized representatives. This would include his/her Attorney-in-Fact and any other party authorized by the User to receive his/her Data.
  • In the event that the User is proposing to purchase a property from TANDYREALTY  which TANDYREALTY  is offering for sale, it may disclose User’s Data to the Vendor of that property in order for User’s offer to be assessed.
  • Companies that provide support services for the purposes of protecting TANDYREALTY ’s legitimate interests. User’s Data remains protected when TANDYREALTY ’s service providers use it. TANDYREALTY  only permits service providers to use User’s information in accordance with its instructions, they will have appropriate measures in place to protect your information. TANDYREALTY ’s service providers include marketing and market research companies, IT and telecommunication service providers, software development contractors, data processors, debit/credit card companies, computer maintenance contractors, printing companies, property contractors, document storage and destruction companies, business advisers, debt collection agencies, accountants, auditors and other consultants, including legal advisers.
  • Statutory and regulatory bodies (including central and local government) and law enforcement authorities. These bodies include the likes of The Data Protection Commissioner/Authorities, the Property Regulatory Authorities, the Police Authorities/Enforcement Agencies, the Revenue Commissioner and the US, EU and other designated authorities in connection with combating financial and other serious crime.

 

7. LINKS, OTHER SITES AND SOCIAL MEDIA ON THE WEBSITE

The Website may, from time to time, contain links to and from other websites and web platforms. In addition, Third Parties’ websites may also provide links to the Website. The User when following a link to any of those websites or web platforms, should note that those websites and web platforms have their own privacy policies and that TANDYREALTY  does not accept any responsibility or liability for those policies. The User is encouraged to check those policies before he/she submits any Data to those websites. TANDYREALTY  does not accept, and it disclaims, any responsibility for the privacy statements and information protection practices of any Third Party website (whether or not such website is linked on or to the Website). These links are provided to the Users for convenience purposes only, and he/she accesses them at his/her own risk. It is the User’s responsibility to check the Third Party website’s privacy statements before he/she submits any Data to their websites.

The Website may also have “plugins” (such as the Facebook “share” or “like” button) to Third Party sites or offer login (such as login with Facebook) through a Third Party account. Third Party plugins and login features, including their loading, operation, and use, are governed by the privacy policy and terms of the Third Party providing them.

 

8. DURATION OF HOLDING OF DATA

The length of time TANDYREALTY holds your Data depends on a number of factors, such as regulatory and statutory requirements. Other considerations are the type of data TANDYREALTY  holds about the User, whether the Data is required for a legal dispute and whether the User or a regulatory authority asks TANDYREALTY  to keep it for a valid reason.

As a general rule, TANDYREALTY  keeps User’s information for a period of 3 (Three) years. Nevertheless, TANDYREALTY  shall delete the Data of a User prior to the elapsing of the 3-year period in case this User will request so unless there is a legally valid reason not to delete the Data.

 

9. NON-PROVISION OF INFORMATION BY THE USER TO TANDYREALTY

Sharing information with TANDYREALTY is in both User’s interest and TANDYREALTY ’s. TANDYREALTY  needs User’s information in order to provide its services to the User, fulfil any contracts it has with the User, to manage its business for its legitimate interests and to comply with its legal obligations.

The User can choose not to share information with TANDYREALTY  but must understand that this may limit the services we are able to provide to you. TANDYREALTY  may not be able to provide the User with certain services that he/she requests.

 

10. THE LEGAL BASIS FOR TANDYREALTY USING USER’S DATA

TANDYREALTY  will use User’s Data and may share that Data where:

  • Its use is necessary for relation to a service or a contract that the User has entered into or because he/she has asked for something to be done so that he/she can enter into a contract with TANDYREALTY  or so that it can provide a service to the User.
  • Its use is in accordance with TANDYREALTY  legitimate interests. Where TANDYREALTY  processes User’s information for its legitimate interests, it ensures that there is a fair balance between its legitimate interest and User’s fundamental rights and freedoms. TANDYREALTY  may use User’s Data to manage its everyday business needs, including internal reporting, market research, to progress and respond to legal claims, to ensure appropriate IT security and to prevent fraud. TANDYREALTY ’s legitimate interest here is the effective management of TANDYREALTY ’s business. TANDYREALTY  may use User’s Data for marketing reasons, i.e. to update User in relation to property related matters. TANDYREALTY ’s legitimate interest here is to connect with User and to update User on properties and services it provides which may be of interest to the User. The User will always have an option to unsubscribe from marketing communications every time TANDYREALTY contacts him/her.
  • Its use is necessary because of a legal obligation that applies to TANDYREALTY .
  • The User has consented to the using of his/her data (including special categories of Data) in a specific way.
  • Where the User has made clearly sensitive categories of Data about User’s public.
  • Where the processing of special categories of Data is necessary for the establishment, exercise or defence of legal claims.

 

11. PROCESSING OF DATA OUTSIDE THE EUROPEAN UNION (EU)

User’s information is stored on secure systems within the premises of TANDYREALTY  and with providers of secure information storage. TANDYREALTY  does not generally transfer information about Users outside the EU.

In certain circumstances, TANDYREALTY  may allow the transfer of information about a User outside the EU by its service providers, but only if they agree to act solely on its instructions and to protect User’s information to the same standard that applies in the EU. Where TANDYREALTY  authorises the processing/transfer of a User’s Data outside of the EU, it requires User’s Data to be protected to at least EU standards.

 

12. USER’S RIGHTS UNDER GDPR

User has several rights in relation to how TANDYREALTY  uses User’s Data and it has significant obligations in this regard.

User has the right to:

  • Find out if TANDYREALTY  uses his/her information, to access his/her information and to receive copies of the information it has about him/her. When User contacts TANDYREALTY  to ask about his/her information, TANDYREALTY  may ask him/her to identify himself/herself. This is to help protect User’s Data. If User makes his/her request electronically, TANDYREALTY  will, where possible, provide the relevant information electronically unless User asks it otherwise.
  • Request that inaccurate information is corrected, and incomplete information updated.
  • Object to particular uses of his/her Data where the legal basis for TANDYREALTY ’s use of User’s Data is TANDYREALTY ’s legitimate business interests. However, doing so may have an impact on the services TANDYREALTY can/is willing to provide.
  • Object to use of User’s Data for direct marketing purposes.
  • Have User Data deleted or its use restricted – User has a right to this under certain circumstances.
  • Obtain a transferable copy of certain Data which can be transferred to another provider, known as “the right to data portability”. This right applies where Data is being processed based on consent or for the performance of a contract and the processing is carried out by automated means. The right also permits the transfer of Data directly to another provider where technically feasible.
  • Withdraw consent at any time, where any processing is based on consent. If User withdraws his/her consent, it will not affect the lawfulness of processing based on his/her consent before its withdrawal.

 

TANDYREALTY  shall process User’s request without undue delay. In most instances, TANDYREALTY  will process User’s request within one calendar month. If TANDYREALTY  is unable to deal with User’s request fully within a Calendar Month (due to the complexity or number of requests), it may extend this period by a further two Calendar Month period. Should this be necessary, TANDYREALTY  will explain the reasons why.

The user has also the right to complain to TANDYREALTY, the Data Protection Commissioner or another supervisory or regulatory authority. If User has a complaint about the use of his/her Data, he/she should let TANDYREALTY  know and TANDYREALTY  shall seek to resolve his/her issue as soon as possible. If User wishes to make a complaint to TANDYREALTY, he/she may do so in person, by telephone, in writing or by email. The User must be assured that all complaints received by TANDYREALTY  will be fully investigated. TANDYREALTY  asks that User supplies as much information as possible to help it to resolve his/her complaint quickly.

 

13. PROCESS OF DATA AND OBJECTION BY THE USER

TANDYREALTY  may process the Data of a User provided that that User has not objected to TANDYREALTY using his/her Data in any way.

 

14. CHANGES TO TANDYREALTY ’s PRIVACY POLICY

TANDYREALTY  will update this Data Protection Privacy Policy from time to time. Any changes will be made available on this Guide.

 

15. CONTACT DETAILS OF THE CYPRUS DATA PROTECTION COMMISSIONER

If you wish to raise a complaint regarding our use of your personal data then you can contact the Commissioner for Personal Data, which is the supervisory authority for data protection issues in the Republic of Cyprus. (http://www.dataprotection.gov.cy).

If you do wish to raise a complaint then we would welcome the opportunity to discuss your concerns before you contact the Personal Data Commissioner to see if we can resolve the issue for you.

E-mail:

commissioner@dataprotection.gov.cy

Telephone:

+357 22818456

Postal Address:

P.O. Box 23378, 1682 Nicosia

Website:

www.dataprotection.gov.cy

 

16. Changes to this policy

We may update these policies to reflect changes to the website and customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data.

We welcome any queries, comments or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us.