This Data Protection Privacy Policy shall be effective as and from the 1st March 2020.
This Privacy Policy constitutes the guide according to which G&P manages personal data and outlines the approach of G&P under the General Data Protection Regulation 2018 (GDPR). In this guide it is explained how G&P collects personal information about the Users, how G&P uses it and how the Users can interact with G&P about it.
1. DEFINITIONS
2. REASONS FOR COLLECTION OF INFORMATION BY G&P AND TYPE OF INFORMATION
There are a number of reasons why G&P 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 G&P can offer User the best possible customer experience.
The type of information that G&P may collect from Users includes:
3. HOW G&P COLLECTS INFORMATION ABOUT THE USER'S AND WHEN?
G&P collects information about Users in a number of ways, included but not limited to:
4. USE OF DATA BY G&P
G&P may use User's Personal Data for matters such as confirming his/her identity in order to enable G&P in the processing of an application for one of G&P's services or to improve the User's customer experience with G&P.
Data is used to manage and administer User's account. Personal Data is also used to process transactions.
G&P 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 G&P, legitimate interest or contrary to the Applicable Law. G&P 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.
G&P 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 G&P. Another legitimate interest of G&P 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 G&P understand trends in its customer behaviour and to understand its risks better, including providing management information, operational and data risk management.
G&P 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 G&P'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).
G&P protects User's information with security measures under Applicable Law, and G&P meets international standards in doing so. G&P 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 G&P office premises.
G&P 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, G&P 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.
G&P needs to use User's Data to manage and administer legal and compliance matters within G&P, including compliance with regulatory, legislative and voluntary codes of practice to which G&P has committed. G&P 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, G&P 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 and MOKAS 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.
In relation to properties which G&P offers for sale, legal documentation is uploaded onto the Website by Licensed Lawyers acting on behalf of Vendors. This documentation is uploaded for the sole purpose of allowing interested parties to carry out due diligence prior to placing a bid in relation to a property. The legal documentation will generally only be available to view for the marketing period relating to an auction, unless a property has been sold prior to, or is withdrawn prior to, the auction. If a property is unsold at auction, the legal documents will remain available 7 (Seven) Business Days after the auction.
5. USE OF AUTOMATED PROCESSING OR ANALYTICS
G&P does not use automated processing in relation to the information it collects from the User's as part of its business.
G&P 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
G&P 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:
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 G&P 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. G&P 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 G&P holds your Data depends on a number of factors, such as regulatory and statutory requirements. Other considerations are the type of data G&P holds about the User, whether the Data is required for a legal dispute and whether the User or a regulatory authority asks G&P to keep it for a valid reason.
As a general rule, G&P keeps User's information for a period of 5 (Five) years. Nevertheless, G&P shall delete the Data of a User prior to the elapsing of the 5-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 G&P
Sharing information with G&P is in both User's interest and G&P's. G&P 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 G&P but must understand that this may limit the services we are able to provide to you. G&P may not be able to provide the User with certain services that he/she requests. Thus, G&P may not be able to approve the User to bid on a property when registering for an auction.
10. THE LEGAL BASIS FOR G&P USING USER'S DATA
G&P will use User's Data and may share that Data where:
11. PROCESSING OF DATA OUTSIDE THE EUROPEAN UNION (EU)
User's information is stored on secure systems within the premises of G&P and with providers of secure information storage. G&P does not generally transfer information about Users outside the EU.
In certain circumstances, G&P 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 G&P 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 G&P uses User's Data and it has significant obligations in this regard.
User has the right to:
G&P shall process User's request without undue delay. In most instances, G&P will process User's request within one calendar month. If G&P 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, G&P will explain the reasons why.
The user has also the right to complain to G&P, 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 G&P know and G&P shall seek to resolve his/her issue as soon as possible. If User wishes to make a complaint to G&P, he/she may do so in person, by telephone, in writing or by email. The User must be assured that all complaints received by G&P will be fully investigated. G&P 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
G&P may process the Data of a User provided that that User has not objected to G&P using his/her Data in any way.
14. CHANGES TO G&P's PRIVACY POLICY
G&P will update this Data Protection Privacy Policy from time to time. Any changes will be made available on this Guide.
15. CONTACT DETAILS OF G&P AND ITS DATA PROTECTION OFFICER
Should the User have any questions about how his/her Data is gathered, stored, shared or used, or if he/she wishes to exercise any of his/her Data rights, he/she can check G&P's Privacy Policy or contact its Data Protection Officer at:
E-mail:
Stelios.p@gplazarou.com
Telephone:
+357 22 024949
Postal Address:
27, Alamanas Street, PC 2547 Dhali, Nicosia
16. CONTACT DETAILS OF THE CYPRUS DATA PROTECTION COMMISSIONER
Should the User not be satisfied with how G&P is dealing with User's complaint, he/she should contact the Cyprus Data Protection Commissioner at:
E-mail:
commissioner@dataprotection.gov.cy
Telephone:
+357 22818456
Postal Address:
P.O. Box 23378, 1682 Nicosia
Website: