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Privacy Policy

Imatech Properties LTD

Effective Date: 13/08/2026
Last Updated: 13/08/2026

1. Introduction

Imatech Properties LTD (“Imatech Properties”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, retain and protect personal data when you visit or interact with our website at https://imatechproperties.com/ (the “Website”), communicate with us, submit an enquiry, or otherwise interact with us in connection with our property and investment-related activities.

This Privacy Policy is intended to comply with:

  • Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”);
  • the Cyprus Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of Such Data, Law 125(I)/2018, as amended;
  • applicable provisions of the Cyprus Law on the Regulation of Electronic Communications and Postal Services, Law 112(I)/2004, as amended;
  • Directive 2002/58/EC on privacy and electronic communications, as implemented in Cyprus; and
  • other applicable Cyprus and European Union data-protection and privacy legislation.

The GDPR establishes, among other matters, requirements relating to lawful processing, transparency, data minimisation, retention, security and data-subject rights. Cyprus Law 125(I)/2018 supplements the GDPR within the Republic of Cyprus.

2. Identity of the Data Controller

For the purposes of the GDPR, the data controller responsible for the processing described in this Privacy Policy is:

Imatech Properties LTD
Company Registration No.: ΗΕ 298904
Registered Address: Arxiepiskopou Makariou C 79, Imatech House, 3rd Floor, Aradippou, 7102, Larnaca, Republic of Cyprus
Website: https://imatechproperties.com/
Telephone: +357 97 879005

For privacy enquiries or requests concerning your personal data, please contact us using the details above.

Unless we notify you otherwise, Imatech Properties LTD acts as the controller of personal data collected through the Website.

3. Scope of This Privacy Policy

This Privacy Policy applies principally to visitors to our Website and persons who contact or correspond with Imatech Properties in connection with our business.

Our Website is primarily an informational website promoting property, real-estate investment and related activities in Cyprus. It is not presently intended to function as an online transactional platform or customer-account system.

If we introduce online customer accounts, e-commerce functionality, payment processing or other material new processing activities, this Privacy Policy should be updated before or at the time those features are introduced.

4. Categories of Personal Data We May Collect

Depending on how you interact with us, we may process the following categories of personal data.

4.1 Identity Data

This may include:

  • first name;
  • surname;
  • title; and
  • any other identifying information that you voluntarily provide to us.
 

4.2 Contact Data

This may include:

  • email address;
  • telephone or mobile number;
  • postal address, where relevant; and
  • preferred means of communication.
 

4.3 Enquiry and Correspondence Data

Where you contact us regarding a property, investment opportunity or other matter, we may process:

  • the content of your enquiry;
  • information concerning the property or service in which you are interested;
  • correspondence between you and Imatech Properties;
  • meeting or appointment information; and
  • other information you voluntarily provide to us.
 

You should avoid providing sensitive or unnecessary personal information through general Website enquiry forms.

4.4 Technical and Device Data

When you access the Website, our systems and service providers may automatically receive certain technical information, including:

  • Internet Protocol (“IP”) address;
  • browser type and version;
  • device type;
  • operating system;
  • time zone or approximate geographic location derived from technical information;
  • Website access times;
  • referring URL;
  • pages visited;
  • session information;
  • diagnostic information; and
  • security and server-log information.
 

4.5 Usage and Analytics Data

Subject to applicable cookie and consent requirements, we may collect information about how visitors use the Website, such as:

  • pages viewed;
  • navigation paths;
  • time spent on particular pages;
  • Website interactions;
  • traffic sources; and
  • aggregated Website-performance information.
 

4.6 Marketing Preference Data

Where applicable, we may process:

  • whether you have consented to receive marketing communications;
  • your marketing preferences;
  • records of consent;
  • requests to unsubscribe; and
  • records of objections to direct marketing.
 

4.7 Business Contact Data

If you interact with us in a professional or commercial capacity, we may process your:

  • employer or organisation;
  • job title;
  • professional contact details; and
  • relevant business correspondence.
 

4.8 Data We Do Not Ordinarily Collect Through the Website

As the Website is presently informational, we do not ordinarily require visitors to create user accounts or provide payment-card information, account passwords or billing information through the Website.

If those functions are introduced in future, appropriate privacy information will be provided and this Privacy Policy will be updated as required.

5. How We Collect Personal Data

We may collect personal data:

5.1 Directly From You

For example, when you:

  • complete a contact or enquiry form;
  • telephone us;
  • email us;
  • request information about a property or service;
  • arrange a meeting;
  • communicate with our employees or representatives; or
  • subscribe to marketing communications, where such functionality is offered.
 

5.2 Automatically Through the Website

Certain technical information may be generated automatically through:

  • web servers;
  • security systems;
  • log files;
  • cookies;
  • similar technologies; and
  • analytics tools, where enabled in accordance with applicable consent requirements.
 

5.3 From Third Parties

Where lawful and relevant to our business, we may receive personal data from:

  • professional advisers;
  • business partners;
  • property owners or developers;
  • property-related service providers;
  • referral partners;
  • publicly available sources; or
  • technical, hosting, analytics or communications providers.
 

Where personal data has not been obtained directly from you and Article 14 GDPR applies, we will provide the information required by that Article within the applicable period unless an exemption applies.

6. Purposes and Lawful Bases for Processing

We process personal data only where we have a lawful basis under Article 6 GDPR.

6.1 Responding to Enquiries and Providing Requested Information

Purpose: To respond to enquiries, communicate with prospective clients, arrange meetings and provide information about properties or services.

Lawful basis:

  • Article 6(1)(b) GDPR, where processing is necessary to take steps at your request before entering into a contract; and/or
  • Article 6(1)(f) GDPR, our legitimate interests in operating our business and responding to persons who contact us.
 

6.2 Managing Business and Client Relationships

Purpose: To administer and develop relationships with prospective clients, clients, suppliers, professional advisers and other stakeholders.

Lawful basis:

  • Article 6(1)(b) GDPR where necessary for contractual or pre-contractual purposes; and/or
  • Article 6(1)(f) GDPR, based on our legitimate interests in managing business relationships.
 

6.3 Website Administration and Security

Purpose: To operate, maintain, secure and troubleshoot the Website; detect abuse or malicious activity; and protect our information systems.

Lawful basis: Article 6(1)(f) GDPR, based on our legitimate interests in ensuring the security, integrity, availability and proper operation of our Website and systems.

6.4 Website Analytics and Performance Measurement

Purpose: To understand Website usage, measure performance and improve our content and services.

Lawful basis:

  • Article 6(1)(a) GDPR where consent is required for analytics cookies or comparable technologies; and
  • where legally permitted, Article 6(1)(f) GDPR for strictly limited processing that does not require consent.

Non-essential cookies or comparable technologies will not be placed or accessed before the required consent has been obtained. Under section 99(5) of Cyprus Law 112(I)/2004, storage of or access to information on a user’s terminal equipment generally requires consent, subject to the statutory exceptions for transmission and strictly necessary services.

6.5 Direct Marketing

Purpose: Where appropriate, to send you information concerning our properties, services, investment opportunities or related business developments.

Lawful basis: Where required, Article 6(1)(a) GDPR — your consent.

Where applicable law permits direct marketing to existing customers without fresh consent, we will rely on the relevant statutory exception only where its requirements are satisfied and an easy, free method of objection is provided.

Cyprus electronic-communications legislation generally requires prior consent for unsolicited direct marketing by email, while providing a limited existing-customer exception for the marketing of similar products or services subject to specified opt-out requirements.

You may withdraw consent or object to direct marketing at any time.

6.6 Legal and Regulatory Compliance

Purpose: To comply with legal obligations, lawful requests from competent authorities and applicable regulatory requirements.

Lawful basis: Article 6(1)(c) GDPR.

6.7 Establishment, Exercise or Defence of Legal Claims

Purpose: To protect our rights, property and legitimate interests and to establish, exercise or defend legal claims.

Lawful basis: Article 6(1)(f) GDPR and, where applicable to special-category data, Article 9(2)(f) GDPR.

6.8 Corporate Transactions

Purpose: To facilitate a corporate restructuring, merger, acquisition, investment, financing, transfer of assets or similar legitimate corporate transaction.

Lawful basis: Article 6(1)(f) GDPR, subject to appropriate safeguards.

7. Legitimate Interests

Where we rely on Article 6(1)(f) GDPR, we consider whether:

  1. there is a legitimate business purpose;
  2. the processing is necessary to achieve that purpose; and
  3. your interests, rights and freedoms override our interests.

You may object to processing based on legitimate interests as described below.

8. Special Categories of Personal Data

We do not intentionally request special categories of personal data through the general Website.

Special-category data includes information concerning matters such as health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data used for unique identification, and sex life or sexual orientation.

Please do not provide such information through general Website forms unless it is genuinely necessary.

If we need to process special-category data, we will do so only where a lawful basis under Article 6 GDPR and an applicable condition under Article 9 GDPR exist.

9. Children

The Website is directed primarily at adults interested in property and investment-related information.

We do not knowingly use the Website to solicit personal data from children.

If you believe that a child has provided personal data to us inappropriately, please contact us so that we may investigate and take appropriate action.

10. Cookies and Similar Technologies

The Website may use cookies and similar technologies.

Cookies are small data files that can be placed on or accessed from a visitor’s device.

We may use the following categories:

Strictly Necessary Cookies

These cookies are necessary for core Website functionality, security, network management or services specifically requested by the user.

Where the statutory exemption applies, consent is not required for these cookies.

Analytics Cookies

Analytics cookies help us understand how visitors interact with the Website.

Where applicable law requires consent, these cookies will remain disabled until you provide consent.

Functionality Cookies

These technologies may remember preferences or enable enhanced Website functionality.

Where consent is legally required, they will be used only after consent has been obtained.

Advertising or Marketing Cookies

If advertising or behavioural-marketing technologies are introduced, they will be activated only in accordance with applicable consent and transparency requirements.

You should be given the ability to accept or reject non-essential cookies and to change your preferences.

11. Recipients and Disclosure of Personal Data

We may disclose personal data where necessary to appropriately selected recipients, including:

  • Website hosting and infrastructure providers;
  • IT and cybersecurity providers;
  • email and communications providers;
  • Website-development and maintenance providers;
  • analytics providers, where lawfully enabled;
  • cloud and data-storage providers;
  • professional advisers, including lawyers, accountants and auditors;
  • insurers;
  • property developers, property owners or professional counterparties where necessary in connection with an enquiry and where legally permitted;
  • competent public, regulatory, judicial, law-enforcement or governmental authorities where disclosure is required or permitted by law;
  • companies within the Imatech group where necessary for legitimate administrative or business purposes and subject to applicable data-protection safeguards; and
  • parties involved in a legitimate corporate transaction.

Where a recipient processes personal data on our behalf as a processor, we will put in place appropriate contractual arrangements in accordance with Article 28 GDPR.

We do not sell personal data.

12. International Transfers

Some of our service providers may process personal data outside the European Economic Area (“EEA”).

Where personal data is transferred to a country outside the EEA, we will ensure that a lawful transfer mechanism under Chapter V GDPR is available.

Depending on the destination and circumstances, safeguards may include:

  • an adequacy decision adopted by the European Commission under Article 45 GDPR;
  • Standard Contractual Clauses (“SCCs”) adopted by the European Commission under Article 46 GDPR;
  • appropriate supplementary technical, contractual or organisational measures where necessary;
  • Binding Corporate Rules where applicable; or
  • a specific derogation under Article 49 GDPR where legally available.

Where SCCs are used, we will assess the transfer as required by applicable EU data-protection law and implement supplementary safeguards where necessary.

You may contact us for further information regarding the relevant transfer safeguards.

13. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including applicable legal, accounting, compliance and dispute-resolution requirements.

Unless a longer or shorter period is justified in the circumstances, our indicative retention approach is:

  • General enquiries that do not lead to an ongoing business relationship: normally up to 24 months after the enquiry is closed.
  • Prospective-client and property enquiries: normally up to 24 months after the last meaningful interaction, unless continued retention is justified by an active opportunity or business relationship.
  • Client and contractual records: for the duration of the relationship and thereafter for the period required by applicable legal, tax, accounting and limitation requirements.
  • Marketing records: until consent is withdrawn or you object, together with a suppression record where necessary to ensure that your preference continues to be respected.
  • Cookie consent records: for the period reasonably necessary to demonstrate consent and manage preferences.
  • Security and server logs: normally for a limited operational period appropriate to cybersecurity, troubleshooting and fraud-prevention requirements.
  • Legal-dispute records: until the matter and any relevant limitation or enforcement period has expired.
 

Specific statutory or operational circumstances may require a different retention period.

When personal data is no longer required, we will delete, anonymise or securely dispose of it as appropriate.

14. Data Security

We implement appropriate technical and organisational measures designed to provide a level of security appropriate to the risks presented by the processing.

Measures may include, as appropriate:

  • access controls;
  • authentication controls;
  • role-based permissions;
  • secure hosting;
  • encryption in transit and, where appropriate, at rest;
  • firewalls and security monitoring;
  • software and system updates;
  • backup and recovery procedures;
  • malware protection;
  • confidentiality obligations;
  • processor due diligence;
  • contractual security obligations;
  • incident-management procedures; and
  • staff awareness and access-management procedures.

No internet-based system can be guaranteed to be completely secure. We therefore cannot warrant absolute security, but we take proportionate measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

15. Personal Data Breaches

Where we become aware of a personal-data breach, we will assess and manage it in accordance with Articles 33 and 34 GDPR and applicable Cyprus law.

Where required, we will notify the competent supervisory authority and, where the applicable legal threshold is met, affected individuals.

16. Your Rights Under the GDPR

Subject to the conditions and exemptions established by applicable law, you have the following rights.

16.1 Right of Access

You may request confirmation as to whether we process your personal data and obtain access to that data and related information.

16.2 Right to Rectification

You may request correction of inaccurate personal data and completion of incomplete personal data.

16.3 Right to Erasure

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

This right is not absolute and may not apply where continued processing is necessary for a legal obligation, legal claims or another lawful ground.

16.4 Right to Restriction

You may request restriction of processing in circumstances specified by Article 18 GDPR.

16.5 Right to Data Portability

Where processing is based on consent or contract and carried out by automated means, you may have the right to receive personal data you provided to us in a structured, commonly used and machine-readable format and, where technically feasible, have it transmitted to another controller.

16.6 Right to Object

Where processing is based on Article 6(1)(e) or 6(1)(f) GDPR, you may object on grounds relating to your particular situation.

We will cease the relevant processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms or the processing is required for legal claims.

16.7 Direct Marketing Objection

You have an absolute right to object at any time to the processing of your personal data for direct-marketing purposes, including profiling related to such marketing.

If you object, we will stop processing your personal data for those purposes.

16.8 Withdrawal of Consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

16.9 Automated Decision-Making

You have rights under Article 22 GDPR in relation to certain decisions based solely on automated processing that produce legal effects or similarly significantly affect you.

We do not currently use the Website to make such solely automated decisions about visitors.

17. Exercising Your Rights

Requests may be submitted to:

Postal address: Imatech Properties LTD, Arxiepiskopou Makariou C 79, Imatech House, 3rd Floor, Aradippou, 7102, Larnaca, Republic of Cyprus.

We may request information reasonably necessary to verify your identity.

We will respond within the periods prescribed by applicable data-protection law. Under the GDPR, controllers ordinarily have one month to respond to data-subject requests, subject to the permitted extension for sufficiently complex or numerous requests.

18. Right to Lodge a Complaint

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

In Cyprus, the supervisory authority is the:

Office of the Commissioner for Personal Data Protection
15 Kypranoros Street
1061 Nicosia
Republic of Cyprus

Postal Address: P.O. Box 23378, 1682 Nicosia
Telephone: +357 22 818456
Email: commissioner@dataprotection.gov.cy

The Commissioner’s official website states that complaints should be submitted using the appropriate complaint form.

Your right to complain to the Commissioner is without prejudice to any other administrative or judicial remedy available to you.

19. Third-Party Websites

The Website may contain links to websites operated by third parties.

We are not responsible for the privacy practices of independent third-party websites. When you leave our Website, you should review the privacy information provided by the relevant third party.

20. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

  • changes in our processing activities;
  • changes to Website functionality;
  • new service providers or technologies;
  • legal or regulatory developments; or
  • improvements to our privacy-governance practices.

The current version will be published on the Website with its effective or last-updated date.

Where changes materially affect the processing of personal data, we will take additional transparency or consent measures where required by law.

21. Contact Us

For questions about this Privacy Policy or the processing of your personal data, contact:

Imatech Properties LTD
Company Registration No.: ΗΕ 298904
Arxiepiskopou Makariou C 79
Imatech House, 3rd Floor
Aradippou, 7102
Larnaca
Republic of Cyprus

Telephone: +357 97 879005
Website: https://imatechproperties.com/

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