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Privacy Policy

EliteEdge Ltd
Last updated: 14/09/2026

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1. Who we are

EliteEdge Ltd ("EliteEdge", "we", "us", "our") is a real estate development and property management company registered in the Republic of Cyprus.

  • Registered address: Q City Center, D.N. Dimitriou, Larnaca 6022, Cyprus

  • Company registration number: [INSERT HE NUMBER]

  • Email: info@eliteedge.com.cy

  • Telephone: +357-24811777

We are the data controller for the personal data described in this policy. This means we decide why and how your personal data is processed, and we are responsible to you and to the supervisory authority for that processing.

If you have any question about this policy or wish to exercise your rights, contact us at info@eliteedge.com.cy.

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2. What this policy covers

This policy applies to personal data we collect when you:

  • submit our contact form on eliteedge.com.cy or any of its landing pages;

  • submit an instant lead form in one of our advertisements on Facebook or Instagram;

  • message us on WhatsApp, or contact us by telephone or email;

  • meet us at a viewing, sales meeting, exhibition or property event;

  • subscribe to our newsletter or download a brochure or price list;

  • enter into a reservation, sale or property management agreement with us;

  • browse our website (cookies — see section 10).

It applies to prospective buyers, buyers, investors, tenants, suppliers, agents and website visitors.

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3. The personal data we collect

Depending on how you interact with us, we may collect:

  • Identity and contact data — first name, last name, telephone number, email address, country of residence, preferred language.

  • Inquiry data — the project you asked about, your budget range, unit type and size preferences, intended use (residence, investment, rental), purchase timeline, financing needs, and any notes from our conversations with you.

  • Correspondence — emails, WhatsApp messages, contact form submissions, and notes of calls and meetings.

  • Transaction and contract data — where you proceed to a reservation or purchase: contract details, payment records, bank details, property and title information.

  • Identification and compliance data — where you proceed to a purchase: passport or ID copy, proof of address, source-of-funds documentation and related records that we are legally required to obtain.

  • Marketing preferences — your consents, and whether you have opted out of any communication.

  • Technical data — IP address, device and browser type, pages visited, referral source, advertising identifiers, cookie data.

We do not seek to collect special category data (such as health, religion or political opinions). Please do not send us such information unless we specifically ask for it.

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4. Where we get your data from

  • Directly from you, when you complete a form, message us or speak to us.

  • From Meta Platforms (Facebook and Instagram), when you submit an instant lead form in one of our advertisements. Meta passes us the details you chose to submit. Meta's own processing of your data as a platform user is governed by Meta's privacy policy, over which we have no control.

  • From our website analytics and advertising tools, where you have consented to non-essential cookies.

  • From third parties, such as real estate agents, introducers, or our partner developers, where you have asked them to put you in touch with us or agreed to be introduced.

 

5. Why we use your data, and our legal basis

Under the GDPR we must have a lawful basis for each use of your data. Ours are as follows.

Responding to your inquiry. To answer the question you asked us — sending project information, price lists, floor plans and availability, and arranging viewings and calls. We also follow up with you about the project you enquired about, by phone, email and WhatsApp. Legal basis: steps taken at your request prior to a contract (Art. 6(1)(b)), or our legitimate interest in responding to inquiries (Art. 6(1)(f)).

Marketing other EliteEdge projects. To tell you about other EliteEdge projects, offers and events that you did not specifically enquire about. Legal basis: your consent (Art. 6(1)(a)).

Referring you to a partner developer. Where our projects do not match your budget or requirements — see section 6. This serves both your interest in finding a suitable property and our commercial interest in the referral. Legal basis: your consent (Art. 6(1)(a)).

Performing our agreements with you. To prepare and perform reservation, sale, rental or property management agreements. Legal basis: performance of a contract (Art. 6(1)(b)).

Legal and regulatory compliance. To carry out customer due diligence, identity verification and source-of-funds checks, and to keep accounting and tax records. Legal basis: legal obligation (Art. 6(1)(c)), under Cyprus anti-money-laundering, tax and company law.

Security and legal claims. To secure our website and systems, prevent fraud, and establish or defend legal claims. Legal basis: legitimate interest (Art. 6(1)(f)); legal claims (Art. 9(2)(f) where relevant).

Advertising and website measurement. To understand how our website and advertising perform and to spend our budget sensibly. Legal basis: your consent for non-essential cookies (Art. 6(1)(a)).

Where we rely on legitimate interest, we have assessed that our interest does not override your rights and freedoms. You may ask us for a summary of that assessment, and you may object at any time (section 11).

 

6. Referrals to partner developers and partner companies

Sometimes the properties we have available do not match what you are looking for most often because your budget, timeline or preferred location is different from what our current projects offer. In those cases we may know another developer or company whose properties fit better.

We will only pass your details to such a partner if you have first agreed to it. In practice this means:

  • We will tell you that our project does not fit, and ask whether you would like an introduction.

  • Where we can, we will name the partner company before you decide.

  • Only if you say yes will we share your details — and we will share only what the partner needs to contact you and understand your requirement: your name, your contact details, and the budget and property preferences you told us about. We do not share your identification documents, financial records or contract data.

  • You can change your mind at any time, before or after the introduction, by telling us or the partner. Withdrawing your agreement does not affect sharing that already took place before you withdrew.

  • If you do not agree, nothing is shared, and it makes no difference to how we deal with you.

Important: once a partner receives your details, that partner becomes an independent data controller for its own use of your data. It is responsible for contacting you lawfully, for giving you its own privacy notice, and for honouring your rights against it. We are not responsible for what a partner does with your data after the introduction, although we only work with partners who commit in writing to handling it lawfully and to using it solely for the introduction you agreed to.

We never sell your personal data, to partners or to anyone else.

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7. Who else we share your data with

We share personal data with the following categories of recipients, only as far as necessary:

  • Our service providers, acting on our instructions under written data processing agreements - including our website platform and hosting provider, our email and CRM systems, our telephony and messaging providers, our IT support and our cloud storage provider.

  • Our advertising and analytics providers, including Meta Platforms and Google, in connection with our advertising and website measurement, where you have consented to the relevant cookies.

  • Our property management partner, where you have purchased a unit and opted into rental management, to operate the rental of your property.

  • Our professional advisers — lawyers, accountants, auditors, banks and insurers - where needed for a transaction or to take advice.

  • Partner developers and companies, only on the basis described in section 6.

  • Public authorities and regulators, including the Cyprus tax authorities, the Land Registry, banks conducting anti-money-laundering checks, and law enforcement, where we are legally required to disclose.

  • A purchaser of our business or assets, if we are ever sold, merged or restructured, in which case your data would remain subject to protections equivalent to this policy.

 

8. Transfers outside the EEA

Some of our providers process data outside the European Economic Area, including in the United States, Israel and the United Kingdom. Where we transfer your data outside the EEA, we rely on one of the following safeguards:

  • an adequacy decision of the European Commission covering the destination country; or

  • the European Commission's Standard Contractual Clauses, together with any additional measures required; or

  • another safeguard permitted by Chapter V of the GDPR.

You may request a copy of the relevant safeguard by contacting us.

 

9. How long we keep your data

  • Inquiries that do not lead to a purchase — 24 months from your last contact with us, then deleted.

  • Marketing contact data — until you withdraw consent or object, and in any event no more than 36 months from your last engagement with us.

  • Record of your agreement to a partner referral — for as long as we retain the underlying inquiry, as evidence of your consent.

  • Suppression list (people who asked not to be contacted) — indefinitely, as this is the only way to make sure we honour your request.

  • Contract, transaction and accounting records — 6 years from the end of the relationship, or longer where tax or company law requires.

  • Anti-money-laundering and identification records — 5 years from the end of the business relationship, as Cyprus law requires.

 

10. Cookies and similar technologies

Our website uses cookies and similar technologies. Some are essential — they are needed to serve the site, keep it secure and remember your language. These are always active.

We also use non-essential cookies and tracking technologies, which are only set where you consent through our cookie banner:

  • Analytics — Google Analytics and our website platform's own analytics, to understand how visitors use the site.

  • Advertising — the Meta Pixel and Google Ads tags, which allow us to measure the results of our advertising on Facebook, Instagram and Google, and to show our ads to people who have visited our site.

Where these are active, information about your visit is shared with Meta Platforms Ireland Ltd and Google Ireland Ltd, who process it as described in their own privacy policies.

You can change or withdraw your cookie choices at any time through the cookie banner or your browser settings. You can also manage how Meta and Google use your data for advertising through your Facebook, Instagram and Google ad settings.

 

11. Your rights

Under the GDPR you have the right to:

  • Access the personal data we hold about you, and receive a copy;

  • Rectify data that is inaccurate or incomplete;

  • Erase your data ("right to be forgotten"), where we no longer have grounds to keep it;

  • Restrict our processing while a dispute about accuracy or legitimacy is resolved;

  • Object to processing based on legitimate interest — and to object to direct marketing at any time, absolutely, in which case we will stop immediately;

  • Data portability — receive data you gave us in a machine-readable format, or have it sent to another controller;

  • Withdraw consent at any time, where we rely on consent, without affecting the lawfulness of processing before withdrawal;

  • Not be subject to automated decision-making producing legal or similarly significant effects. We do not carry out such decision-making.

To exercise any right, contact us at [privacy@eliteedge.com.cy]. We will respond within one month. We may ask you to verify your identity first. Exercising your rights is free of charge unless a request is manifestly unfounded or excessive.

Right to complain. If you believe we have handled your data unlawfully, you may lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus — [VERIFY CURRENT CONTACT DETAILS: www.dataprotection.gov.cy] - or with the supervisory authority in the EU country where you live or work. We would appreciate the chance to address your concern first.

 

12. Security

We apply technical and organisational measures appropriate to the risk, including access controls limiting lead and client data to staff who need it, encryption in transit, secured cloud storage, and contractual confidentiality obligations on our staff and providers. No transmission over the internet is completely secure, and we cannot guarantee absolute security.

 

13. Children

Our services are directed at adults. We do not knowingly collect data from anyone under 18. If you believe a minor has given us personal data, contact us and we will delete it.

 

14. Changes to this policy

We may update this policy. The current version is always published at eliteedge.com.cy/privacy-policy with the date of last update. Where a change materially affects how we use your data — for example a new purpose - we will notify you directly and, where required, obtain your consent.

 

15. Contact

EliteEdge Ltd
Q City Center, D.N. Dimitriou, Larnaca 6022, Cyprus
Email: [privacy@eliteedge.com.cy] · info@eliteedge.com.cy
Telephone: +357-24811777

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