Privacy Policy

1. Data Controller Information

In accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Controller responsible for processing your personal data is Ark Noah's Holdings Ltd., registered in the Republic of Cyprus. Our registered office is located at Andrea Themistokleous 12, Limassol 3041, Cyprus. For any data protection inquiries, you may contact us at [email protected].

2. Data We Collect

We collect personal data only when strictly necessary for providing our high-yield real estate and investment services. This includes:

• Identity Data: Full name, title, and corporate affiliation.
• Contact Data: Email address, telephone number (+357 777 88 758 / direct contacts), and postal address.
• Technical Data: IP address, browser type and version, time zone setting, browser plug-in types, operating system, and platform via essential cookies.
• Usage Data: Information on how you interact with our website, properties, and services.

3. Lead Capture & Direct Marketing

When you submit an inquiry via our website forms, you explicitly consent to the collection of the submitted data for the purpose of receiving targeted real estate investment consultations. We employ a strict double opt-in protocol for newsletters and off-market offers. You maintain the absolute right to withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

4. Cookies & Tracking Technologies

Our website utilizes cookies to enhance user experience, perform analytics, and ensure site security. We segregate cookies into 'Strictly Necessary', 'Analytical', and 'Marketing'. Upon your first visit, you are presented with a transparent consent banner. You may revoke or modify your cookie preferences through your browser settings.

5. Purpose and Legal Basis for Processing

We process your data on the following legal bases:

• Consent: Where you have freely given explicit consent (e.g., subscribing to newsletters).
• Contractual Necessity: Processing required to fulfill an agreement or take steps prior to entering a contract (e.g., arranging property viewings).
• Legal Obligation: Compliance with Cyprus and EU anti-money laundering (AML) and Know Your Customer (KYC) regulations.
• Legitimate Interests: For internal business administration, IT security, and preventing fraud.

6. Data Retention Policy

Your personal data is retained only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under Cyprus Corporate Law, basic client information and transactional data are held for a minimum of 6 years.

7. Your GDPR Rights

Under the GDPR, you possess comprehensive rights regarding your personal data:

• The Right of Access: You may request a copy of the personal data we hold about you.
• The Right to Rectification: You may request correction of inaccurate data.
• The Right to Erasure ('Right to be Forgotten'): In certain circumstances, you may request the deletion of your data.
• The Right to Restrict Processing: You may ask us to suspend the processing of your data.
• The Right to Data Portability: You may request your data be transferred to another party in a structured format.
• The Right to Object: You may object to processing based on legitimate interests or direct marketing.

8. Third-Party Sharing and International Transfers

We do not sell your personal data. We may share data with vetted third-party service providers (e.g., legal counsel, IT hosting, CRM systems) strictly under data processing agreements. If data is transferred outside the European Economic Area (EEA), we ensure a similar degree of protection is afforded by implementing Standard Contractual Clauses (SCCs) approved by the European Commission.

9. Data Security

We have deployed robust security measures encompassing SSL encryption, access controls, and regular system audits to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

10. Contact and Complaints

Should you wish to exercise any of your rights or file a complaint regarding our data handling practices, please email [email protected]. You also retain the ultimate right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus.