1. Data Controller

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and applicable Cyprus data protection legislation, the data controller responsible for the processing described in this Privacy Policy is:

References in this policy to “Premier”, “we”, “us” or “our” mean Premier Property Management Ltd.

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data processed through www.premier.cy and in connection with enquiries about Premier's property management and related services.

It includes information submitted through our contact forms, Rental Income Estimate form, Management Proposal form, LiveChat and other communications with us.

If you subsequently enter into a property management agreement with Premier, additional personal data may be processed as necessary to administer and perform that contractual relationship.

3. Personal Data We Collect

The personal data we collect depends on how you interact with Premier and the information you choose to provide.

Contact and identity information

• Name.
• Email address.
• Telephone number.
• Correspondence and messages sent to us.

Property information

When you request a rental estimate, management proposal or discuss a property with us, we may process information including:

• Property location.
• Property type.
• Number of bedrooms and bathrooms.
• Swimming pool information.
• Distance from the beach.
• Property features and facilities.
• Current holiday rental status.
• Current management arrangements.
• CTO registration status where relevant.
• Other property information you choose to provide.

Technical and website usage information

Depending on your consent choices and the technology being used, we may process technical information such as:

• IP address.
• Browser and device information.
• Operating system.
• Approximate geographic information derived from technical data.
• Pages viewed and interactions with the website.
• Referring website or advertising source.
• Cookie and similar technology identifiers.
• Advertising and conversion information.

We do not ask you to provide special category personal data, such as health information, racial or ethnic origin, religious beliefs or similar sensitive information, through our standard website enquiry forms.

4. How We Collect Personal Data

We may collect personal data:

• Directly from you when you complete a form on our website.
• When you communicate with us by email, telephone or LiveChat.
• When you request a Rental Income Estimate or Management Proposal.
• Through cookies and similar technologies, subject to applicable consent requirements.
• From advertising and analytics platforms where permitted by law and your consent choices.
• During subsequent communications concerning a potential or existing business relationship with Premier.

5. Why We Process Personal Data and Our Lawful Bases

Under the GDPR, Premier must have a lawful basis for processing personal data. The basis depends on the purpose for which the data is being used.

Where we rely on legitimate interests, we consider whether those interests are necessary and proportionate and whether your interests, rights or freedoms override our interests.

6. Website Forms and Enquiries

Premier currently operates website forms including:

• General Contact enquiries.
• Rental Income Estimate requests.
• Management Proposal requests.

Information submitted through these forms is sent to Premier by email so that our team can respond to your request.

Website enquiry information may subsequently be entered into Monday.com, which Premier uses as part of its internal enquiry, workflow and customer relationship management processes.

Please avoid including unnecessary sensitive or confidential personal information in free-text message fields.

7. Cookies, Analytics and Advertising Technologies

Our website uses cookies and similar technologies. Some are necessary for the website to operate, while others may be used for analytics, advertising and measurement purposes.

Where required by law, non-essential technologies are used subject to your consent choices.

Cookiebot by Usercentrics

We use Cookiebot by Usercentrics to manage cookie consent and allow visitors to choose which categories of non-essential cookies they wish to permit.

Google Analytics

Google Analytics may be used to help us understand how visitors use our website, including information about visits, pages viewed and website interactions.

Google Ads

Google Ads technologies may be used to measure advertising performance and conversions and, where enabled and lawfully permitted, support advertising activities.

Meta Pixel

We use Meta Pixel technology in connection with Meta advertising. Subject to applicable consent requirements, this can help us measure actions taken on our website following interaction with advertising and understand advertising performance.

LiveChat

Our website may provide LiveChat functionality. If you choose to use LiveChat, information you provide through the conversation and associated technical information may be processed in order to provide the chat service and respond to your enquiry.

Further details about cookies and how to manage your preferences are provided in our Cookie Policy.

8. Who We Share Personal Data With

Premier does not sell your personal data.

We may share or make personal data available to service providers where reasonably necessary to operate our website, business or services.

Categories of recipients may include:

• Monday.com — internal enquiry, workflow and customer relationship management.
• Google — analytics, advertising and conversion measurement where applicable.
• Meta — advertising and advertising measurement where applicable.
• Cookiebot by Usercentrics — cookie consent management.
• LiveChat — website chat functionality.
• Website hosting, email, security, anti-spam, IT and technical service providers.
• Professional advisers such as accountants, lawyers or other advisers where reasonably necessary.
• Courts, regulators, law enforcement bodies, public authorities or other parties where disclosure is required or permitted by applicable law.

Where another organisation processes personal data on our behalf as a processor, we require the processing to be subject to appropriate contractual and data protection requirements where required by law.

9. International Transfers

Some of the technology providers used by Premier operate internationally. Personal data may therefore be processed in countries outside Cyprus or the European Economic Area (EEA).

Where GDPR applies and personal data is transferred to a country outside the EEA, Premier will seek to ensure that the transfer is made in accordance with applicable data protection requirements. Depending on the destination and provider, this may include reliance on an applicable European Commission adequacy decision or appropriate safeguards recognised under the GDPR.

Where appropriate safeguards are relied upon, these may include approved contractual safeguards such as the European Commission's Standard Contractual Clauses.

You may contact us at info@premier.cy if you require further information about safeguards relevant to your personal data.

10. How Long We Keep Personal Data

We keep personal data only for as long as reasonably necessary for the purposes for which it was collected and for any additional period required to meet legal, regulatory, tax, accounting, contractual or dispute-resolution requirements.

The appropriate retention period depends on factors including:

• The nature of the information.
• The purpose for which it was collected.
• Whether an enquiry develops into a business relationship.
• Whether information is required to perform a contract.
• Applicable statutory or regulatory requirements.
• The need to establish, exercise or defend legal claims.

Enquiry information that is no longer required should be periodically reviewed and deleted or anonymised when there is no longer a legitimate or legal reason to retain it.

11. Security of Your Personal Data

Premier uses reasonable technical and organisational measures intended to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, access or other misuse.

These measures may include access controls, website security, anti-spam measures and limiting access to information to persons who reasonably require it for their work.

No method of transmission over the internet or electronic storage can be guaranteed to be completely secure. We therefore cannot guarantee absolute security.

12. Your Rights Under the GDPR

Subject to the conditions and exceptions provided by applicable law, you may have the following rights in relation to your personal data:

Right of access

You may request confirmation of whether we process your personal data and request access to personal data we hold about you.

Right to rectification

You may ask us to correct inaccurate personal data or complete information that is incomplete.

Right to erasure

In certain circumstances, you may request deletion of your personal data.

Right to restriction

In certain circumstances, you may ask us to restrict how your personal data is processed.

Right to object

Where processing is based on legitimate interests, you may have the right to object to that processing based on your particular situation.

Right to data portability

Where the applicable legal requirements are met, you may have the right to receive certain personal data in a structured, commonly used and machine-readable format and to have that information transmitted to another controller.

Right to withdraw consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Cookie consent can also be changed or withdrawn using the cookie settings available on our website.

Data protection rights are subject to conditions and exceptions under applicable law and do not apply in every circumstance.

13. Right to Lodge a Complaint

If you have concerns about the way Premier processes your personal data, we encourage you to contact us first so that we can try to resolve the issue.

You also have the right to lodge a complaint with the competent data protection supervisory authority.

Premier Property Management Ltd is established in Cyprus. The supervisory authority in Cyprus is the Office of the Commissioner for Personal Data Protection.

You may obtain current contact and complaints information directly from the Commissioner's official website.

14. Direct Marketing

Premier does not automatically enrol people who submit an enquiry, Rental Income Estimate request or Management Proposal request into an email newsletter or general marketing mailing list.

If we introduce optional email marketing in the future, we will apply the appropriate consent, transparency and opt-out requirements before using personal data for that purpose.

This does not prevent us from communicating with you directly about an enquiry you have made, a requested service or an existing business relationship where such communication is otherwise lawful.

15. Children's Privacy

Premier's website and property management services are intended for adults and property owners and are not directed at children.

We do not knowingly seek to collect personal data from children through our property owner enquiry forms.

16. Automated Decision-Making

Premier does not currently use personal data submitted through its property owner enquiry forms to make decisions that produce legal or similarly significant effects solely through automated processing.

Advertising and analytics platforms may use automated technologies for their own measurement, audience or advertising functions, subject to applicable consent choices and the relevant provider's terms and privacy practices.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our website, services, technology, suppliers or legal obligations.

The “Last updated” date at the top of this page shows when the policy was most recently revised.

Where a change materially affects how we process personal data, we will take any additional steps required by applicable law.

18. Contact Premier About Your Personal Data

For questions about this Privacy Policy, our handling of personal data or to exercise a data protection right, contact: