PRIVACY POLICY

M.Residence Ltd, is a Cyprus company with registered number HE330147 and registered office address at Nikou Kranidioti 7, Egkomi, 2411, Nicosia, Cyprus and EU VAT number CY10330147C (hereinafter “MResidence”, “we”, “us”, or “our”). M.Residence Ltd is a Registered & Licensed Real Estate Agency in Cyprus Council of Real Estate Agents with Registration No. 791 – Licence No. 363/E.

If you have any questions, comments and/or requests regarding this Privacy Policy or wish to obtain more details in relation to the personal data we process about you, please contact us by sending an email to hello@mresidence.com.

• when you visit and/or use our MResidence Site;
• (when you complete our registration form;
• when you log in to our MResidence Site using an authentication system;
• when you post materials or upload content;
• when you communicate with employees, agents, representatives, or directors of MResidence via the MResidence Site;
• when you take part in surveys or report a problem with our MResidence Site;
• when you contact with us via email, text, post or other ways of communication; and/or
• when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

For both Browsers and Members

For Members only

We will only use and share your information where it is necessary for us to provide you with our lawful services in accordance with this Privacy Policy. We would like to ensure that you fully understand why your information may be used. We will only use your personal data when the applicable local law allows us to.

• where we need to perform our services to you, as necessary in accordance with our MResidence Site’s Terms & Conditions;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation; and/or
• where you have given us your consent.

Below, we describe these circumstances in further detail.

• Performance of our services to you
  • Provision of services

    We may collect and process your personal data where it is necessary in order to present our MResidence Site and its contents to you and enable you to access and use the MResidence Site, including any interactive features on our MResidence Site and to provide you with information, products or services that you request from us, to enable you to communicate with employees, agents, representatives and directors of MResidence via the MResidence Site.

    Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your MResidence Account and/or provide you with the services we provide to our Members.

  • Customer management (Members Only)

    We may collect and process your personal data where it is necessary in order to manage a Member’s account, to provide customer support and notices to Members about their account and/or subscription, including expiration and renewal notices, and inform you about any notices about changes to our MResidence Site or any products or services we offer or provide through it.

• Legitimate interests
  • Customization of content

    We may collect and process your personal data where it is necessary in order to measure and perform research and analysis about your use or, or interest in, our MResidence Site content and/or services, so as to develop and display content and advertising tailored to your interests on our MResidence Site.

  • Analytics

    We may collect and process your personal data where it is necessary in order to determine whether users of the MResidence Site are unique, or whether the same user is using the MResidence Site on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed and demographic patterns.

  • Functionality and security

    We may collect and process your personal data where it is necessary to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, spam, abuse, security incidents, harmful activities, illegal activities, or intellectual property infringement, to conduct security investigations and risk assessments.

  • Other legitimate interests

    In addition to the above, we may process your data, to the extent required for our business needs in order to:

    • develop new services on our MResidence Site as well as analyze and target new markets;
    • enforce our Terms & Conditions and other policies and protect our legal rights and interests (including legal claims and preparing our defense in litigation);
    • monitor, maintain and improve internal business processes, information and data, technology and communication solutions and services;
    • ensure network information security, including monitoring Browsers’ and Members’ access to our information technology for the purpose of preventing cyber-attacks, unauthorized use of MResidence Site and prevention or detection of crime;
    • send you relevant marketing information (including details of other services provided by us which we believe may be of interest to you), but only where you are Member of the MResidence Site (For more information, see paragraph “Choices About How We Collect, Use and Disclose Your Personal Information”) below;
    • monitor the performance and effectiveness of our services and the MResidence Site;
    • assess the quality of our customer services;
    • verity or authenticate information or identifications provided by you (such as to compare your identification photo to another photo you provide); and
    • Resolve any disputes with any of our Members and enforce our agreements with third parties.
• For compliance with legal obligations

  When you visit and/or use and/or register in our MResidence Site (and throughout your relationship with us), we are required to comply with certain legal and regulatory obligations which may involve the processing of your personal data. This may include processing to:

  • perform checks, including checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent, where required;
  • comply with laws relating to fraud;
  • identify other infringements of our Terms & Conditions; and
  • manage contentious regulatory matters, investigations and litigation.
• You have provided your consent

  We will ask for your consent when we wish to provide marketing information to you in relation to our services which we believe may be of interest and of benefit to you, but only where you are a Browser and where applicable, where you are a Member.

  We will also ask for your consent when we collect sensitive data for you, where you are a Member, as described in this Privacy Policy.

  You have the right to revoke your consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.

• Performance of a contract

  We will process your personal information for the performance of a contract i.e. to enter into a contract with you or to perform a contract that we entered into with you.

It is our policy not to use or share personal data about you in ways unrelated to those described in this Privacy Policy without also providing you with an opportunity to opt out or otherwise object to such unrelated uses. However, we may disclose personal data about you, or information regarding your use of the services or the MResidence Site to third parties for any of the reasons set out hereinabove, or if we are legally required to do so, or if we are authorized under our contractual and statutory obligations. When we disclose your personal data to service providers, we will ensure that they are bound by a contract requiring them to comply with their GDPR obligations. Under the circumstances referred to above, recipients of personal data may be, for example:

• governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings, legal process, governmental requests or investigations by such parties or in order to enable the MResidence to comply with its legal and regulatory requirements. We specifically reserve the right to disclose any and all information to law enforcement in the event that a crime is committed or suspected or detected or if we are compelled to do so by lawful criminal, civil or administrative process, discovery requests, subpoenas, court orders or writs, to enforce applicable terms of service, including investigation of potential violations thereof, to detect, prevent or otherwise address security or technical issues, protect against harm to the rights, property or safety of our company, our users, our employees, or others; or to maintain and protect the security and integrity of our MResidence Site or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
• buyers or other legal successors in the event of an acquisition, merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, insolvency, liquidation or similar proceeding, in which personal information held by us about our MResidence Site’s Browsers and Members is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to ensure that the entity to which we transfer your personal data uses it in a manner that is consistent with this Privacy Policy.
• legal, accountants, banks and other professional consultants.

We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction any other anonymized information. We also may share such aggregated information with third-parties for conducting general business analysis. This information does not contain any personal data and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising, for regulatory compliance, industry and market analysis, research, marketing and other business purposes.

Please note that we have never sold and will never sell your personal data to third parties.

Financial information (including personal information) that you have provided to us will only be shared with our third-party processors and banks in order to initiate and complete any orders and service requests made through the MResidence Site, your MResidence Account or to make payments owed to you by MResidence. All credit card transactions and such are processed with industry standard encryption through third party processors who only use your financial information and personal information for that purpose. All financial data and related personal information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions and policies of a third party. All such information provided to a third party is subject to their terms and conditions.

We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your personal data from unauthorized access and disclosure. For instance, only authorized employees are permitted to access personal data, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your personal data between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal data. However, please be advised that we cannot fully eliminate security risks associated with the storage and transmission of personal data as we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining this information.

You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the MResidence Site.

If you know or have reason to believe that your MResidence Account credentials have been lost, stolen, misappropriated, or otherwise compromise or in case of actual or suspected unauthorised use of your MResidence Account, please contact us following the instructions in the “Our communication with you” section below.

We may review, scan or analyse your communications on the MResidence Site for fraud prevention, risk assessment, compliance with a legal or regulatory obligation, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods when reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on MResidence’s legitimate interest in ensuring compliance with applicable laws and our Terms & Conditions preventing fraud, promoting safety and improving and ensuring the adequate performance of our services.

Some of our external third parties are based outside the European Economic Area (“EEA”) so the processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use service providers outside the EEA, including the United States, we may use model clauses or specific contracts approved by the European Commission which give personal data the same protection it has in the European Union.

We may additionally, in rare occasions, transfer your personal data to a party outside the EEA where we have your prior explicit consent to do so or where such transfer is necessary for the provision of our services to you.

We may process your personal data so as to inform you about existing and/or future services that may be of interest to you by sending you periodic announcements with details on existing and/or new services and/or programs, surveys, sweepstakes, contest, or other promotional activities or events sponsored by MResidence or its third-party partners.

You have the right to object at any time to the processing of your personal data for marketing purposes, by sending us an email at hello@mresidence.com or by clicking at the opt-out link at the bottom of any marketing emails or we send you. If we send you a text message, opt-out instructions will be included in the text message we will send you.

We can only use your personal data to promote our services to you if we have your explicit consent to do so, or in certain cases such as for example when you are a Member of our MResidence Site, if we consider that it is in our legitimate interest to do so. You may also occasionally receive marketing communications from our affiliates, but only provided you have given your explicit consent in receiving such communications.

Even if you inform us that you no longer wish to receive marketing material, you will still receive from us system notices and other information specifically related to your account from time to time.

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Where we no longer need to process your personal data for purposes set out in this Privacy Policy, we will delete your personal data from our systems. However, we may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and that your data are only used for those purposes. The period for which we keep your personal information that is necessary for compliance and legal enforcement purposes varies and depend on the nature of our legal obligations and claims in the individual case.

Where permissible, we will also delete your personal data upon your request. Information on how to make a deletion request can be found under the paragraph “Your data protection rights” below.

If you have questions about our data retention practices, please contact us electronically by sending as an email at hello@mresidence.com.

Subject to local law, you have certain rights regarding the personal data we collect, use or disclose and that is related to you. We want to make sure you are aware of your rights in relation to the personal data we process about you. We have described those rights and the circumstances in which they apply further below.

• Right to Access: This enables you to get access or receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
• Right to Data Rectification and Correction: If you believe that any of the information that we hold about you is inaccurate or incomplete, you have a right to request that we correct and rectify the inaccurate personal information.
• Right to be Forgotten / Erasure: You may request that we delete your personal information if you believe that:
  • we no longer need to process your information for the purposes for which it was provided;
  • we have requested your permission to process your personal information and you wish to withdraw your consent; or
  • we are not using your information in a lawful manner.

  Please note that if you request the erasure of your personal information:

  • We may retain some of your personal information as necessary for our legitimate interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a MResidence Account for fraud and safety reason, we may retain certain information from that MResidence Account to prevent that Member from opening a new MResidence Account in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, MResidence may keep some of your information for tax, legal reporting and auditing obligations.
  • Because we maintain the MResidence Site to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
• Right to object: You have the right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you exercise your right to object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedom or for the establishment, exercise and defence of legal claims.

  You also have the right to object where we are processing your personal data for direct marketing purposes. This also includes profiling in as much as it is related to direct marketing.

  If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.

  Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, where requested, delete your personal data. Please note that if you object us processing your personal data, we may have to suspend the services we provide to you.

• Right to Restriction of Processing: You have the right to request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data if:
  • it is not accurate; or
  • it has been used unlawfully but you do not want us to delete it; or
  • it is not relevant any more, but you want us to keep it for use in possible legal claims; or
  • you have already asked us to stop using your personal data but you are waiting for us to confirm if we have legitimate grounds to use your personal data.

  Please note that if you request us to restrict processing of your personal data, we may have to suspend the services we provide to you.

• Right to data portability: Where we have requested your permission to process your personal data or you have provided us with information for the purposes of entering into a contract with us, you have the right to receive the personal data you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provided to you.

If we ask for your consent to use your personal data, you can withdraw your consent at any time. Please note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of our MResidence Site and our services.

Please note that some requests to delete certain personal data will require the deletion of your account as a Member as the provision of Member accounts is inextricably linked to the use of certain personal data (e.g. your email address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honour your request.

To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us electronically by sending us an email at hello@mresidence.com or by post at M.Residence Ltd, Nikou Kranidioti 7, Egkomi, 2411, Nicosia, Cyprus.

We endeavour to address all your requests promptly.

We remain dedicated to the protection of your data and we want to be clear about the type of information collected, helping you make choices about your privacy. You may:

• access/modify the information in your profile provided during registration;
• access/modify the information in your profile provided during registration;
• block cookies, including cookies associated with our services, by activating or deactivating the related cookies on your browser. Please note, however, that if you choose to disable all cookies (including essential cookies) you may not be able to access all or part of our MResidence Site. Please see our Cookies Policy for more information.

We strive to provide you with choices regarding the personal information you provide to us.

• You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our MResidence Site because such information may be required in order for you to register as a Member; request products or services; participate in a contest, promotion, survey; ask a question; or initiate other transactions on our MResidence Site.
• You can limit the information you provide to MResidence. Participation in promotions and marketing programs is voluntary.
• You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly. Please see our Cookies Policy for more information.
• You may opt out of the DoubleClick cookie or Google Analytics by visiting the advertising opt-out page or by downloading and installing the browser plug-in available at Google Analytics opt-out page. Please see our Cookies Policy for more information.
• When you register on our MResidence Site, you may be given a choice as to whether you want to receive email messages, text messages, newsletters or both about product updates, improvements, special offers, or containing special distributions of content by us. If you no longer want to receive commercial or promotional emails or newsletters from us, you will need to avail yourself of the unsubscribe mechanism set out in the applicable communication. It may take up to seven (7) days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
• You may opt out of interest-based advertising on mobile devices by activating the “Limit Ad Tracking” or equivalent feature offered by your mobile platform. It will transmit a signal to us and to third-parties that indicates your data should not be used for interest-based advertising.
• You may opt-out of the collection and use of information for ad targeting by updating your Facebook account ad settings.
• If you submit personal information, you may delete your account with us at any time. If you delete your account, your Personal Information and any and all other account related information including, but not limited to, user profile data, sharing data and any other data, or content specifically associated with your account will no longer be accessible by you. After deleting your account, if you choose to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.

If you have any questions about this Privacy Policy or our information-handling practices, please contact us electronically at hello@mresidence.com or by post at M.Residence Ltd, Nikou Kranidioti 7, Egkomi, 2411, Nicosia, Cyprus.

If you wish to lodge a complaint about how your personal data is used by the MResidence, you may contact us electronically at the email address hello@mresidence.com or by post at M.Residence Ltd, Nikou Kranidioti 7, Egkomi, 2411, Nicosia, Cyprus.

Upon receipt of your complaint, we will investigate it and respond to you within a reasonable time. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the collection, use and disclosure of personal data that cannot be resolved by an individual and us.

You also have the right to complain to the data protection supervisory authority of the country in which you reside, provided that such country is a Member State of the European Union or is located within the EEA.

Our MResidence Site is not directed to individuals under the age of eighteen (18) or the applicable age of majority in the jurisdiction from which the MResidence Site is accessed and we do not knowingly collect personal data from minors. If you become aware that your child has provided us with personal data, please contact us electronically at hello@mresidence.com. If we become aware that a minor has provided us with personal data, we will take steps to remove such information and terminate that person’s account immediately.

Our MResidence Site may include links to third-party websites or services, such as third-party integrations, co-branded services, plug-ins and applications (“Third-Party Partners”). MResidence Site does not own or control these Third-Party Partners and by clicking on those links or enabling those connections may allow third parties to collect or share data about you. These Third-Party Partners will have their own rules about the collection, use, and disclosure of information. We do not control these third-party websites and are not responsible for their privacy statements. We specifically disclaim responsibility for their content, privacy practices and terms of service, and we make no endorsements or representations about their accuracy, content or thoroughness. When you leave our MResidence Site, we encourage you to read the privacy policy of every website you visit.

Parts of MResidence Site may use third-party services such as Google Maps/Earth services, including the Google Maps API(s). When using the Google Maps feature, information is transferred to Google and analysed for their purposes. As a rule, this information includes your IP address and the possibility that it will be transferred to one of Google’s servers in the USA. Use of these respective services is subject to their privacy policies such as Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

We may permit users with accounts on certain third-party services, including but not limited to, social networking, search, sharing, and other services delivered by third parties, to bypass the standard applicable registration process. We currently have the option to authenticate yourself with your existing profile on one of the following social networks, Facebook, and Google, and finally registering or logging in.

If you connect through an authorized third-party service, you will be able to use your third-party login information to log in to your account or access our content and MResidence Site. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third-party services that may be triggered by using these third-party login services. Please review their terms of service and privacy policies carefully before using third party login functionality to access our MResidence Site.

By using any third-party services to log in to your account or access our MResidence Site, you permit us to access, store and use all information related to your third-party account that may be accessible to us through the third-party service, including through its application programming interface (API), pursuant to this Privacy Policy.

We only collect your information from linked third-party accounts to the extent necessary to ensure the adequate performance of our contact with you, or to ensure that we comply with applicable laws, or with your consent.

For further information, please read the data protection information of the respective provider:

• Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland, is responsible for Facebook.com in Europe; http://www.facebook.com/policy.php more information on the data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications as well as http://www.facebook.com/about/privacy/your-info#everyoneinfo
• Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA; https://www.google.com/policies/privacy/partners/?hl=en.

Mavronichis reserves the right to update, revise, amend and/or modify this Privacy Policy at any time in accordance with this provision in order to reflect any changes to the way in which we process your personal data or changing legal requirements. If we make changes to these Terms, we will post the revised Privacy Policy on the MResidence Site and update the “Last Updated” date at the top of this Privacy Policy. If we make any material changes to this Privacy Policy, we may elect to notify you of the modifications via email. If you disagree with the revised Privacy Policy, you may terminate this Agreement with immediate effect by stop using the MResidence Site, and if you are a Member, by cancelling your MResidence Account. We will inform you about your right to terminate the Agreement in the notification email. If you do not terminate the Agreement or cancel your MResidence Account after the date the revised Privacy Policy becomes effective, your continued access to or use of the MResidence Site will constitute acceptance of the revised Privacy Policy.

As we have briefly mentioned in this Privacy Policy, our MResidence Site uses small files known as cookies to make it work better in order to improve your experience.

To find out more about how we use cookies, please see our Cookies Policy.

We do not guarantee error-free performance under this Privacy Policy. We will use reasonable efforts to comply with this Privacy Policy and will take prompt corrective action when we learn of any failure to comply with our Privacy Policy. We shall not be liable for any incidental, consequential or punitive damages relating to this Privacy Policy.