Privacy Policy

1. Who is responsible for your data

The controller of your personal data is Amphialos Real Estate Consulting, a real estate consultancy based in Cyprus ("we", "us"). For any question about your data, or to exercise your rights, contact us:

We have not appointed a Data Protection Officer, as we are not required to. Please send data protection questions directly to the contacts above.

2. What data we process and why

Visiting our website

When you visit the website, our hosting provider automatically processes the technical data needed to deliver the pages and protect the service: your IP address, the date and time of access, the page requested, the referring page, and your browser and operating system. We do not use this data to identify you. Legal basis: our legitimate interest in running a secure, working website (Art. 6(1)(f) GDPR).

Fonts are served from our own server, so your browser does not connect to Google or any other font provider.

Cookies and similar technologies

We only use technologies that the website needs to work:

• NEXT_LOCALE – a cookie that remembers the language version you chose. It is only set when you choose a language different from your browser's, and it is deleted when you close the browser.
• cookie-consent – an entry in your browser's local storage that remembers your choice in the cookie banner, so we don't ask you again on every visit.

We do not use analytics, advertising or social media cookies. If we add optional cookies in the future, such as analytics, we will update this policy first and set them only after you click "Accept all" in the cookie banner. You can change your choice at any time via "Cookie settings" at the bottom of every page. Legal basis for the necessary cookies: our legitimate interest (Art. 6(1)(f) GDPR) and the exemption for strictly necessary storage in the Cypriot law implementing the ePrivacy Directive (Law 112(I)/2004).

When you contact us

If you contact us through the contact form, by email, by phone or on WhatsApp, we process the data you give us. This is usually your name, email address and phone number, the service you are interested in, a preferred date for a consultation and the content of your message, plus anything else you choose to share, such as your budget or the kind of property you are looking for. We use it to reply to you, arrange a consultation and prepare an offer. Legal basis: taking steps at your request before entering into a contract (Art. 6(1)(b) GDPR) and our legitimate interest in answering inquiries (Art. 6(1)(f) GDPR).

When you use our services

If you become our client, we process the data we need to provide our services: investment advice, property search, relocation support and help with legal matters, financing, insurance and rental management. Depending on the service, this may include your identification and contact details, a copy of an identity document, information about your financial situation and financing needs, your property preferences, and the correspondence and documents of the transaction. Legal bases: performance of our contract with you (Art. 6(1)(b) GDPR); compliance with our legal obligations, such as accounting and tax rules and, where they apply to us, anti-money-laundering rules (Art. 6(1)(c) GDPR); and our legitimate interest in establishing, exercising or defending legal claims (Art. 6(1)(f) GDPR).

We do not ask for special categories of data, such as health information. Please do not send us such data unless your matter genuinely requires it.

We usually receive your data directly from you. If someone referred you to us, such as a business partner or another client, we may receive your contact details from them.

We do not sell personal data, and we do not send marketing messages without your consent.

3. Who we share your data with

We share personal data only when necessary, and only with:

• Service providers that process data on our behalf under a data processing agreement: our website host, Vercel Inc., and our email, IT and accounting providers.
• Partners involved in your matter, at your request or with your consent: for example property developers and sellers, lawyers, banks and mortgage brokers, insurers, and relocation and property management providers. They process your data as independent controllers under their own privacy policies.
• WhatsApp: if you contact us on WhatsApp, the service is provided by WhatsApp Ireland Limited, which processes your data under its own privacy policy. If you prefer, email or call us instead.
• Public authorities, courts and our professional advisers, when the law requires it or when it is needed to protect our rights.

4. Transfers outside the European Economic Area

Some of our providers are based outside the European Economic Area, for example Vercel Inc. and Meta Platforms, Inc., the parent company of WhatsApp, in the United States. Such transfers take place only on the basis of a European Commission adequacy decision, such as the EU-U.S. Data Privacy Framework, or of standard contractual clauses approved by the Commission. You can ask us for more information about these safeguards.

5. How long we keep your data

• Technical website data: for the short period our hosting provider needs for security and troubleshooting.
• Inquiries that do not lead to cooperation: up to 24 months after our last contact, in case you come back to the conversation.
• Client data: for the duration of our cooperation, and then for as long as the law requires: accounting and tax records for 6 years from the end of the tax year they relate to, and, where these rules apply to us, anti-money-laundering records for 5 years after the business relationship ends. We may keep data longer if we need it to establish, exercise or defend legal claims, until those claims become time-barred.
• Cookies: the language cookie until you close your browser; your cookie choice until you clear your browser data or change it.

6. Your rights

Under the GDPR, you have the right to:

• access your data and receive a copy of it (Art. 15),
• rectification of inaccurate or incomplete data (Art. 16),
• erasure of your data (Art. 17),
• restriction of processing (Art. 18),
• data portability: receive the data you gave us in a commonly used format, or have it sent to another controller (Art. 20),
• object to processing based on our legitimate interests (Art. 21),
• withdraw your consent at any time, where processing is based on consent; this does not affect processing carried out before the withdrawal (Art. 7(3)).

To exercise your rights, contact us using the details in section 1. We will reply without undue delay, and within one month at the latest. In complex cases this period may be extended by two further months, and we will tell you why. Exercising your rights is free of charge. We may ask you to confirm your identity before we act on a request.

We do not make decisions based solely on automated processing, including profiling, that would have legal or similarly significant effects on you.

7. Right to lodge a complaint

If you believe we process your data unlawfully, you can lodge a complaint with the Cypriot supervisory authority:

• Commissioner for Personal Data Protection, 15 Kypranoros Street, 1061 Nicosia, Cyprus (postal address: P.O. Box 23378, 1682 Nicosia)
• Phone: +357 22 818 456, email: commissioner@dataprotection.gov.cy
• Website: www.dataprotection.gov.cy

You can also complain to the data protection authority of the EU country where you live or work, or where the alleged infringement took place.

8. Do you have to provide your data?

Providing personal data is voluntary. Without it, however, we cannot reply to your inquiry or provide our services. Where the law requires certain data, such as identification under anti-money-laundering rules, we cannot provide the service without it.

Our website and services are not directed at persons under 18, and we do not knowingly collect their data.

9. How we protect your data

We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. The website is served only over an encrypted HTTPS connection, access to client data is limited to the people who need it for their work, and we only work with providers that offer adequate data protection guarantees.

10. Links to other websites

Our website links to other sites, such as those of property developers and publishers of market reports. This policy does not apply to them, so please read their own privacy policies.

11. Changes to this policy

We may update this policy when our services, the law or the technologies we use change. The current version is always available on this page, with the date of the last update at the top.