Privacy Policy

Introduction
Key terms
The scope of this privacy policy
Personal information we collect about you
How your personal information is collected
How and why we use your personal information
Promotional and Marketing Communications
Who do we share your personal information with
Where your personal information is held
How long your personal information will be kept
Transferring your personal information out of the EEA
Your rights
Keeping your personal information secure
How to complain
Changes to this privacy policy
How to contact us

1. Introduction

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (EU) 2016/679 (commonly known as the “GDPR”), which applies across the European Union and we are responsible as the controller of that personal information for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant Cyprus and EU legislation and our professional duty of confidentiality.

2. Key terms

It would be helpful to start by explaining some key terms used in this policy:

we, us, our

AURORAX GROWTH VENTURES LIMITED, a limited liability registered in the Republic of Cyprus, with company registration number HE 431715 and registered office at Florinis 7, GREG Tower, 2 nd floor, 1065 Nicosia, Cyprus

personal information

Any information relating to an identified or identifiable individual.

special categories of personal information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, Genetic and biometric data. Data concerning health, sex life or sexual orientation.

3. The scope of this privacy policy

This privacy policy applies in the following circumstances:

when we provide or we agree to provide our services to actual and prospective clients, which consist of marketing services to investors who invest or look to invest in the real estate market in Cyprus;
when you request information from us or provide information to us;
when you use our website.

4. Personal information we collect about you

We may collect and use the following personal information about you:

Identity Data which includes your first name and last name, title, date of birth and gender and information that enables us to check and verify your identity, such as your identity card or passport number.
Contact Data which includes your email address, mailing address, telephone number and fax number.
Information relating to the matter in which we are instructed to provide our services (see below for more information).
Financial Data which includes billing and bank account details and other data necessary for processing payments.
Transaction Data which includes details about payments and services you have purchased from us.
Usage Data, which includes information about your use of our website and other electronic services.
Feedback and Communications Data, which includes details of any communication you have with us or feedback you give us.
Marketing Data which includes your preferences in receiving marketing material from us, other members of our group and our third party partners.

The information relating to the matter in which you we have been instructed to provide our marketing services includes:

details regarding potential real estate investment opportunities that interest you;
the purpose of the investment that you are looking for;
your budget and any financing needs or arrangements;
whether you will be looking for a legal advisor;
lead source.

We do not usually collect any special categories of personal information about you nor do we collect any information about criminal convictions and offences. If there is good reason to collect or process such personal information, we will inform you of the reason in advance and we will only process such personal information with your explicit consent.

Where we need to collect personal information by law, or in order to be able to provide our products or services to you and you fail to provide that information when requested, this may prevent or delay us from providing our products or services to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Our services are neither aimed at nor intended for children, therefore we do not usually collect and use personal information of children (i.e. individuals who are under the age of sixteen).

5. How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, or by email, and when you fill in any of the forms available on our website. However, we may also collect information:

from publicly accessible sources; and
from cookies on our website – for more information on our use of cookies, please see our cookies policy.

6. How and why we use your personal information

Under data protection law, we can only use your personal information if we have a
proper reason for doing so, e.g.:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party, where your interests and fundamental rights do not override our interests or those of a third party; or where you have given your consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and the legal bases which we rely on to do so:

What we use your personal information for:

To provide our services to you:

Identity Data
Contact Data
Financial Data
Information relating to the matter in which we are instructed to provide our services

Performance of a contract with you or taking steps at your request before entering into a contract
Necessary for our legitimate interests (ensuring that you are provided with the best services we can offer, record, and administer our transactions)
Necessary to comply with our legal and regulatory obligations

To manage payments, fees and charges, and to collect and recover money owed to us:

Identity Data
Contact Data
Financial Data
Transaction Data

Performance of a contract
Necessary for our legitimate interests (for running, administering, and protecting
our business and our rights

To manage our relationship with you or your organisation which will include:

notifying you about changes to how we operate our business or our terms of business deal with you
updating the information we have about you

Identity Data
Contact Data

Performance of a contract with you or to taking steps at your request before entering into a contract
Necessary to comply with our legal and regulatory obligations
Necessary for our legitimate interests (to inform you about our business and keep our records updated)

Gathering and providing information and making filings required by law or relating to audits, enquiries or investigations by regulatory bodies or authorities

Identity Data
Contact Data
Financial Data
Transaction Data

Necessary to comply with our legal and regulatory obligations
Necessary for our legitimate interests (for protecting our rights and defending ourselves in the context of audits, inquiries or investigations administration)

External audits and quality checks

Identity Data
Contact Data
Financial Data
Transaction Data

Necessary to comply with our legal and regulatory obligations
Necessary for our legitimate interests (for maintaining our accreditations and operating at the highest standards)

To improve our website, products and services, marketing, customer relationships and experiences

Transaction Data
Feedback and Communications Data
Marketing Data

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)

Marketing our business and making suggestions and recommendations to you about services and opportunities that may be of interest to you

Identity Data
Contact Data
Transaction Data
Feedback and Competitions Data
Marketing Data

Your consent
Necessary for our legitimate interests (to develop our services and market and grow our business)

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Promotional and Marketing communications

We may use your personal information to send you updates (usually by email or text message) about our services, including investment opportunities that might interest you.

We rely on your consent to send you promotional and marketing communications and we will ask for this consent separately and clearly.

Where you have provided your consent for promotional and marketing communications, you have the right to withdraw it at any time by:

Emailing, calling or writing to us—see below: ‘How to contact us’
using the ‘unsubscribe’ link in emails or ‘STOP’ number in text messages

We will always treat your personal information with the utmost respect and never share it for marketing purposes with other organisations outside our group.

8. Who we share your personal information with

In the normal course of our business, we will share your personal information with developers, real estate agents and other professionals involved in the real estate market.

In addition to the above, we routinely share personal information with:

our professional advisers or consultants, including bankers, legal advisors, auditors and accountants;
service providers who provide information technology and system administration services to us;
external auditors, any person or entity to whom we are required or requested to make such disclosure by any court of competent jurisdiction or by any governmental, taxation or other regulatory authority, law enforcement agency or similar body; and
our own insurers and banks.

We only allow third parties to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

9. Where your personal information is held

Your information is stored in physical files in our premises and also in electronic form in servers located in the EU. However, it may also be held by third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

10. How long your personal information will be kept

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. This includes for example the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to provide our services to you.

Thereafter, we will keep your personal information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you in accordance with the law; and
to keep records required by law.

Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

11. Transferring your personal information out of the EEA

We will most likely not transfer your personal information outside the European Economic Area (EEA), unless there is an international dimension to the services we are providing or you are located outside the EEA.

If we do transfer your personal information out of the EEA, we will ensure a degree of protection similar to that afforded in EEA countries is afforded to it by ensuring at least one of the following safeguards is implemented:

We will transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
Where we transfer your personal information to countries that have not been deemed to provide an adequate level of protection for personal information by the European Commission, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.

If you would like further information please contact us (see ‘How to contact us’ below).

12. Your rights

You have the following rights in relation to your personal information:

Access

The right to be provided with a copy of your personal information.

Rectification

The right to require us to correct any mistakes in your personal information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

To be forgotten

The right to require us to delete your personal information (in certain circumstances). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Restriction of processing

The right to require us to restrict processing of your personal information (in certain circumstances). This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Data portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

To object

The right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

Withdraw consent

The right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

For further information on each of those rights, including the circumstances in which they apply, please contact us or visit the website of the Commissioner for the Protection of Personal Data (www.dataprotection.gov.cy).

If you would like to exercise any of those rights, please:

Email, call or write to us—see below: ‘How to contact us’;
let us have enough information to identify you;
let us have proof of your identity; and
let us know what right you want to exercise and the information to which your request relates.

You will not have to pay a fee to access your personal information or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

14. How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Cyprus is the Commissioner for Personal Data Protection who can be contacted at 1 Iasonos street, 2nd floor, 1082 Nicosia; tel: 22818456; fax: 22304565; Email: commissioner@dataprotection.gov.cy; www.dataprotection.gov.cy.

15. Changes to this privacy policy

This privacy policy was published on January 1st 2024.

We may change this privacy policy from time to time. When we do we will post the updated privacy policy on our website and we will also inform you via email if you are on our mailing list.

16. How to contact us

Please contact us by email if you have any questions about this privacy policy or the information, we hold about you.

Our contact details are shown below:

Email: info@aurorax.digital