1. Introduction

This Privacy Policy explains how SORAGDOOR88 & SHUNA LIMITED (“Company”, “we”, “us”) collects, uses, stores, and shares personal data through this website (“Website”).

The Company is registered in Israel, with registered office at Plot 88, Livadia, Larnaca District, 7060 Cyprus.

By using the Website, you agree to this Privacy Policy.

2. Applicable Legal Framework

We process personal data in accordance with:

• applicable Israeli data protection laws
• the General Data Protection Regulation (where applicable)

Nothing in this Policy limits any mandatory rights under applicable law.

3. Types of Personal Data Collected

We may collect the following categories of data:

3.1 Identification Data

• full name
• nationality
• ID/passport details (if required for transactions)

3.2 Contact Data

• email address
• phone number (including WhatsApp)

3.3 Financial / Transaction Data

• reservation fee details
• payment confirmations
• source of funds information (for AML compliance)

3.4 Property Preferences

• budget
• preferred location
• investment criteria

3.5 Technical Data

• IP address
• browser type
• device information
• cookies and usage data

4. How We Collect Data

We collect data when you:

• fill out forms on the Website
• request property information
• communicate with us
• engage in transactions
• use or browse the Website

5. Purpose of Processing

We use personal data for:

• providing property information and services
• generating and managing Leads
• connecting users with property developers, agents, and service providers
• facilitating transactions (including reservation fees)
• compliance with legal and regulatory obligations
• improving Website performance

6. Legal Basis for Processing (GDPR)

Where applicable under the General Data Protection Regulation, processing is based on:

• user consent
• performance of a contract or pre-contractual steps
• legitimate business interests (including lead generation and referral services)
• legal obligations (AML, regulatory compliance)

7. Lead Sharing and Data Disclosure (Critical Clause)

By using the Website, you expressly acknowledge and agree that:

• your details may be shared with:
• property developers
• property sellers
• real estate agents
• lawyers and financial advisors

for the purpose of facilitating property transactions.

Important:

• such sharing is a core function of the Website
• the Company may distribute Leads at its discretion
• recipients may contact you directly

8. International Data Transfers

Your data may be transferred to and processed in:

• Israel
• the Republic of Cyprus
• other jurisdictions involved in property transactions

We take reasonable steps to ensure appropriate safeguards are in place.

9. Data Retention

We retain personal data:

• as long as necessary for business purposes
• for the duration of any transaction
• for legal, regulatory, and dispute-resolution purposes

Lead data may be retained for up to [3–7 years recommended].

10. Cookies and Tracking

The Website uses cookies to:

• improve user experience
• analyze traffic
• personalize content

Users may disable cookies via browser settings.

11. User Rights

Subject to applicable law, users may have the right to:

• access their personal data
• request correction
• request deletion
• object to processing
• withdraw consent

Requests can be made via the contact details below.

12. Data Security

We implement reasonable technical and organizational measures to protect data, including:

• secure servers
• restricted access
• encryption where appropriate

However, no system is completely secure.

13. Third-Party Responsibility

Once your data is shared with third parties:

• those parties act as independent data controllers
• the Company is not responsible for their data practices

14. Marketing Communications

We may contact users with:

• property opportunities
• investment offers
• updates and promotions

Users may opt out at any time.

15. Compliance with Israeli Law

We comply with applicable Israeli legislation, including:

• Israeli Privacy Protection Law

16. Changes to This Policy

We may update this Privacy Policy at any time.

Continued use of the Website constitutes acceptance of any updates.

17. Contact

For any privacy-related inquiries:

SORAGDOOR88 & SHUNA LIMITED.
Plot 88, Livadia, Larnaca District, 7060 Cyprus.
sales@88residences.com
+972-36006006

18. Direct Contact and Messaging Consent (Calls, WhatsApp, SMS)

By submitting your details on the Website, you expressly consent to being contacted by the Company and/or third parties to whom your data is disclosed (including property developers, agents, and service providers) via:

• telephone calls
• email
• SMS messages
• messaging applications (including WhatsApp or similar platforms)

Scope of Contact

Such communications may include:

• responses to enquiries
• property offers and updates
• transaction-related communications
• marketing and promotional content

Acknowledgment

You acknowledge that:

• communications may be made using automated or manual systems
• contact may occur even if your number is registered on any “do not call” or similar registry, to the extent permitted by law

Opt-Out

You may withdraw your consent at any time by:

• clicking “unsubscribe” (where available)
• contacting us directly

Withdrawal of consent does not affect:

• prior lawful processing
• communications strictly necessary for ongoing transactions

19. High-Net-Worth Individuals and AML Data Handling

Due to the nature of cross-border real estate transactions, the Company may be required to collect and process enhanced personal data for anti-money laundering (AML) and regulatory compliance purposes.

19.1 Types of Data Collected

This may include:

• source of funds documentation
• bank references
• corporate ownership structures
• beneficial ownership information
• identification of politically exposed persons (PEPs)

19.2 Purpose of Processing

Such data is processed for:

• compliance with Cypriot AML laws
• compliance with EU directives
• internal risk assessment and due diligence

19.3 Data Sharing

AML-related data may be shared with:

• legal advisors
• financial institutions
• property developers or counterparties (where required)
• regulatory authorities

19.4 Mandatory Nature

Failure to provide required information may result in:

• refusal to process a transaction
• suspension or termination of services

19.5 Legal Basis

Processing is carried out in accordance with:

• legal obligations
• the General Data Protection Regulation
• applicable Israeli legislation, including the Israeli Privacy Protection Law

“This website uses cookies and similar technologies to provide services, analyze usage, and share your enquiry details with relevant property partners. By clicking ‘Accept’, you consent to the use of cookies and the processing of your data in accordance with our Privacy Policy.”