Privacy Policy (GDPR)

Effective Date: 18 October 2025

This Privacy Policy describes how ZY IMMO Capital Ltd (“we”, “our”, “us”) — an independent SaaS PropTech platform — collects, uses, and protects personal data when users interact with our websites, Telegram-based systems, or other connected digital environments. Our approach to privacy is guided by transparency, security, and respect for every verified participant within our ecosystem.

1 / Who We Are

ZY IMMO Capital Ltd is a limited liability company registered in Cyprus (Reg. No. HE 475591), headquartered at Chrysanthou Mylona 1, Panayides Building, Floor 2, Flat 1, 3030 Limassol, Cyprus. We operate as a data controller under GDPR (EU) 2016/679 and Cyprus Law 125(I)/2018.

2 / What Personal Data We Collect

• Identification and contact details (name, email, country, company, professional role)
• Investor or partner profile data (preferences, budgets, areas of interest)
• KYC and verification documentation (when required by law)
• Technical and operational data from our digital tools (IP, device, language, session logs)
• Optional consent data for communication and platform improvements

3 / How We Use Your Data

Data collected within our ecosystem is used exclusively to support and enhance the digital collaboration process between verified users and licensed professionals. Specifically, we process information to:

• Facilitate investor onboarding and partner introductions
• Manage NDA and legal documentation flows
• Provide secure access to verified projects and platform tools
• Comply with AML/KYC and EU regulatory standards
• Maintain platform integrity, security, and user experience

4 / Legal Basis for Processing

• Contractual necessity — to provide services or information requested by users.
• Legal obligation — for compliance with AML, KYC, and data-protection laws.
• Legitimate interest — ensuring system security, operational efficiency, and fraud prevention.
• Consent — for optional updates and communication preferences.

5 / Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described here or as required by law. KYC and compliance documents are retained securely for up to five (5) years after the end of a verified business relationship, in accordance with Cyprus AML obligations.

6 / Data Sharing

Your data is shared only with verified third-party processors essential to the platform’s operation. These include:

• Cloudinary – encrypted file storage and asset management
• Pipedrive – CRM and workflow automation
• DocuSign – electronic document signature and verification
• Brevo (Sendinblue) – transactional communication tools
• Secure payment processors – for digital onboarding
• Licensed legal or technical partners – after NDA validation and KYC completion

All processors comply with GDPR Art. 28 and contractual confidentiality standards.

7 / International Transfers

Where data is processed outside the European Economic Area, we rely on lawful transfer mechanisms such as EU Standard Contractual Clauses (SCCs) or adequacy decisions. All transfers are audited for GDPR compliance and security equivalence.

8 / Your Rights

• Access, rectification, or deletion of your personal data
• Restriction or objection to processing (Art. 21 GDPR)
• Portability of your information (Art. 20 GDPR)
• Withdrawal of consent for communications
• Lodging a complaint with the Cyprus Commissioner for the Protection of Personal Data

All data-related requests are managed securely within the Telegram-based ZY IMMO Capital platform to ensure traceability and identity verification.

9 / Cookies & Tracking

Our websites use cookies for essential functionality, analytics, and experience enhancement. See our Cookie Policy for full details.

10 / Data Security

We maintain advanced technical and organisational safeguards, including encrypted transfer (HTTPS), multi-level access control, regular security audits, and continuous monitoring of data flows. Access is restricted strictly to authorised personnel and trusted processors.

11 / Policy Updates

This Policy may be updated periodically to reflect legal, operational, or technological developments. The current version and effective date are always available on this page.

12 / Contact & Data Protection

All communication regarding data protection and user rights is managed through the official Telegram platform of ZY IMMO Capital Ltd. This ensures full security, authentication, and record of every request.

© 2025 ZY IMMO Capital Ltd · Reg. No. HE 475591 · Limassol, Cyprus