This Privacy Policy explains how SORAGDOOR88 & SHUNA LIMITED, HE 468953 (hereinafter: the “Company”) collects, uses, stores, and shares personal information through this website (hereinafter: the “Website”).
The Company is a real estate development company engaged in the initiation, planning, development, construction, and marketing of real estate projects in Cyprus, and operates with investors, purchasers, clients, and agents.
The Company respects the privacy of Website users and places the utmost importance on protecting personal information provided to it as part of using the site, its services and systems. Use of the Website constitutes full, informed, and explicit consent to this Privacy Policy.
For the avoidance of doubt, you are under no legal obligation to provide the personal information detailed in this Policy. The provision of such information is made voluntarily and with your full consent, for the purpose of receiving services, establishing contact, and forwarding your inquiry to the relevant parties.
- Collection of Information
1.1. During the use of the Website and/or the Company’s services, the Company may collect, in whole or in part, the following information:
- Contact Details: Email address, telephone number (including WhatsApp).
- Financial and Transaction Information: Reservation fee details, payment confirmations, information regarding the source of funds (for AML – Anti-Money Laundering purposes).
- Real Estate Preferences: Budget, preferred location, investment criteria.
- Technical Information: IP address, browser type, device information, Cookies, and usage data.
- Methods of Information Collection
2.1. Information is collected, inter alia, through the Website, telephone calls, SMS messages, email communications, WhatsApp, social media platforms, advertising systems, external forms, CRM systems, mailing and marketing automation systems, as well as through third parties acting on behalf of the Company.
- Purposes of Processing
3.1. The Company uses personal information for the following purposes:
- Providing information and real estate services.
- Creating, managing, and routing inquiries (leads).
- Connecting users with developers, agents, and relevant service providers in Cyprus.
- Assisting in the execution of transactions (including the collection of reservation/booking fees).
- Compliance with legal and regulatory requirements.
- Operating, securing, and improving the Website’s performance.
Due to the nature of international real estate transactions, the Company and the parties involved in the transaction are required to collect and process enhanced personal information for anti-money laundering purposes and compliance with European and Cypriot regulatory requirements.
- Types of Information Collected for Such Purposes: Documents evidencing the source of funds, banking references, corporate ownership structures, details of beneficial owners and controlling persons, and identification of politically exposed persons (PEPs).
- Purpose and Disclosure: Such information may be shared with lawyers, financial institutions, competent authorities, and developers relevant to the transaction for the purpose of conducting enhanced due diligence procedures.
- Mandatory Nature and Refusal of Service: Failure to provide information required under AML laws may result in refusal to process the transaction, suspension thereof, or immediate termination of the engagement.
- Legal Basis for Processing Personal Information
The Company processes personal information based on one or more of the following legal grounds:
- The user’s consent.
- Performance of a contract or pre-contractual actions.
- Legitimate business interests (including lead generation and referral services).
- Compliance with binding legal obligations (such as anti-money laundering and regulatory compliance requirements).
- Lead Sharing and Disclosure of Information to Third Parties
5.1. By using the Website and providing your details, you expressly acknowledge and agree that your details may be shared with:
- Real estate developers and property sellers.
- Real estate agents and brokers.
- Lawyers, financial consultants, and management companies.
The information is collected for operational, marketing, advertising, and data analysis purposes. In addition, the information may be disclosed in the event of a merger, acquisition, transfer of operations, or structural change of the Company, as well as pursuant to legal requirements, court orders, or instructions of competent authorities, or for the protection of the Company’s rights and/or the rights of third parties.
- International Transfers of Information
6.1. The user acknowledges and agrees that information may be transferred, stored, and processed outside the State of Israel.
- Mailing Lists, Marketing Communications, and Communications Law
7.1. By providing your details on the Website, you expressly consent to the Company, as well as third parties to whom the information is transferred (including developers, agents, and marketers), contacting you and sending you advertisements, investment offers, property updates, and marketing content.
7.2. Communications may be conducted through:
- Telephone calls (including automated dialing systems), email communications, messages, and applications including WhatsApp or similar platforms.
7.3. Exemption from the “Do Not Call Me” Registry:
You hereby confirm that if your telephone number is registered in the Israeli “Do Not Call Me” registry, your inquiry to the Company and the provision of your details constitute an explicit request on your behalf and an active consent to receive marketing calls and sales communications from the Company or its partners, until such time as you expressly withdraw such consent.
- Data Retention and Security
8.1. Data Retention: Information shall be retained for as long as required for business purposes, throughout the duration of the transaction, and for legal and regulatory purposes. Information relating to leads may be retained for up to seven (7) years for documentation purposes.
8.2. Security and Limitation of Liability: Your information shall be stored in the Company’s databases (to the extent that registration thereof is required by law). The Company employs technical and organizational measures to protect personal information. However, no system is completely secure. The Company does not guarantee absolute immunity from unauthorized intrusions and shall not be liable for any direct or indirect damage resulting from unauthorized access to its systems, provided that it acted reasonably and in accordance with accepted industry standards.
- User Rights
9.1. Each user is entitled to contact the Company and request access to personal information held about them in the Company’s databases. Users may request correction, update, or deletion of information, or request cessation of the use of their information for marketing purposes. The Company may refuse such requests where permitted by applicable law.
- Cookies and Tracking Technologies
10.1. The Website uses Cookies and tracking technologies, including Google Analytics, Meta/Facebook Pixel, Google Ads, and additional advertising and analytics tools.
10.2. Blocking Cookies may impair certain functionalities of the Website.
- Amendments to the Policy and Contact Information
11.1. The Company may update this Privacy Policy at any time, at its sole discretion.
Continued use of the Website following publication of any update constitutes acceptance of the updated version.
11.2. For questions, requests, or inquiries regarding privacy matters, you may contact the Company at:
Address:
Arch. Makariou III 22, MAKARIA CENTRE, th floor, office 4024
Email:
sales@88residences.com
Telephone:
+972-3-6006006
