Privacy Policy

About this Policy

This privacy policy and general privacy notice applies to FOX Smart Estate Agency Network Ltd (“FOX”). We at FOX take your privacy seriously. This policy and notice has been drafted in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and applicable Cyprus laws and regulations.

The purpose of this privacy policy is to provide you with all the details relating to your personal data, including the way we collect, process, handle, store and retain personal data and sets out your privacy rights and also explains how the law and our approach to privacy and personal data protects you.

This privacy notice supplements any other privacy notices that we may provide to you at the point that we collect data from you and should be read in conjunction with those notices.
This policy applies to all individuals whose personal data we process, including clients, prospective clients, website visitors, job applicants, service providers, and other third parties who interact with us.

References in this policy to “we”, “us” and “our” are references to Fox. References to “you” and “your” are to the individual/s who is/are providing Personal Data (as defined below) to us.

Contact details

We welcome any comments regarding this Privacy Policy. For any questions or complaints regarding this Policy, please contact our Data Protection Officer (“DPO”) at:

Email: [email protected]

Postal address: 6, Georgiou Davari Street, 2024, Strovolos, Nicosia, Cyprus

We will use reasonable efforts to promptly determine and remedy the problem or the question addressed.

By using the Website you consent to this policy. We are registered with the Information Commissioner’s Office for this purpose.

How we collect personal data

We collect, process, and store personal data that is directly provided to us by you or that we obtain in the course of our interactions with you. This may occur through your visit on our Website or information you provide by email, telephone, in person (e.g. at our offices or property viewings), via property-related forms, during contractual engagements, or through other legitimate business interactions.

Types of personal data collected

The term Personal Data refers to any element or information that can identify a person’s identity or contact information. This also includes cases where one’s identity can be ascertained even indirectly by reference to a factor that is unique to the physical, physiological, genetic, psychological, economic, cultural or social identity of that individual.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data which may include first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, ID number, passport number and gender.
Contact Data which may include billing address, delivery address, email address and telephone numbers.
Financial Data which may include bank account and payment card details.
Transaction Data which may include details about payments to and from you and other details of products and services you have purchased from us.
Technical Data which may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Further financial and/or business information necessarily processed in a project or client contractual relationship with Fox or voluntarily provided by you, such as instructions given, payments made, requests and projects.
Usage Data which may include information about how you interact with and use our website, products and services.
Property Data which may include property-related information such as the type of property, registration number, price, condition, location, size, number of rooms, and preferences for property search or purchase.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We do not intentionally collect or process any Special Categories of Personal Data as defined under Article 9 of the GDPR. These include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning a person’s sex life or sexual orientation.

If such data is provided to us unintentionally (e.g., included in a CV or email), it will be processed only where strictly necessary and in accordance with applicable legal grounds, such as your explicit consent or to comply with legal obligations.

Data Accuracy

It is important that the data that we hold about you is accurate and up to date. In the event that your data changes please notify us so that we can update our records, in the contact details listed above.

Use of your information

We may hold and process personal data that you provide to us in accordance with the GDPR.

The information that we collect and store relating to you is primarily used:

To enable us to provide our services to you, to communicate with you and to meet our contractual commitments to you.
To notify you about any changes to our business, such as improvements to our Website or service/product changes, that may affect our service or relationship with you.
If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you.
Where you have consented to receive such information, to provide information on other parties’ products or services that we feel may be of interest to you.
Where you have consented to receive our e-newsletters to provide that to you.
Where we need to comply with a legal obligation.
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.
for any purpose related and/or ancillary to any of the above or any other purpose for which your Personal Data were provided to us.

Where we collect your data for marketing purposes we will always request your consent, at the point the data is collected, to use your data for that purpose. You can withdraw your consent at any time by clicking the unsubscribe link in our marketing emails or by contacting us at [email protected]. If you prefer not to receive marketing communications, you can also opt-out at the time we collect your data.

We will always obtain your prior consent to sharing your personal data with any third party for their marketing purposes. This may be to enable relevant third parties to advise you of products or services that may be of interest to you.

We will only use your personal data for a reason other than the purpose for which it was originally obtained if we consider that we need to use it for that other purpose and have a legitimate interest in doing so.

Legal Basis for Processing Your Data

We process your personal data based on the following legal grounds under the GDPR:

Consent: When you have explicitly consented to the processing of your data for specific purposes (e.g., marketing communications).
Contractual Necessity: When processing is necessary for the performance of a contract with you (e.g., providing real estate services).
Legal Obligation: When we need to process your data to comply with legal requirements (e.g., tax and anti-money laundering laws).
Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided that your rights and freedoms are not overridden.

You can withdraw your consent at any time by clicking the unsubscribe link in our marketing emails or by contacting us at [email protected]. If you do not wish to receive marketing communications, you can opt-out at the time of data collection or later by contacting us.

Disclosure of your information

There are a range of circumstances where we may disclose your data to third parties. These include:

Regulatory bodies. We may disclose your data to regulatory bodies to enable us to comply with the law and to assist fraud protection and minimise credit risk.
Our Suppliers. We may disclose your data to third parties that are involved in the fulfilment of our services to you.
Third party marketing. Where you have consented for us to do so, we may provide your data to selected third parties who may contact you about their goods or services that you may be interested in.
Business sale. We may disclose your personal data outside of our organisation:
- (a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and
- (b) if FOX’s business is bought by a third party, in which case personal data held by it about its customers will be one of the assets to transfer to the buyer. However, any such transfer will only be on terms that the confidentiality of your personal data is protected and that the terms of this privacy policy will continue to be complied with by the recipient.

Please be advised that we do not reveal information about identifiable individuals to our advertisers, but we may, on occasion, provide them with Aggregated Data (i.e. data that may be obtained from your personal data, but which does not directly or indirectly identify you. This may include Usage Data detailing how you use our Website and the features and areas that you have interacted with) about our Website visitors and customers.

If you do not want us to share your data with third parties you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data. You can do so by contacting us on the contact details listed above.

As part of the services offered to you, for example through our Website, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA) as we use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the EEA, or use servers based outside of the EEA – this is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating outside the EEA who work for one of our suppliers, e.g. our website server host, payment processing provider, or work for us when temporarily outside of the EEA.

A transfer of your personal data may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA.
If you use our service while you are outside the EEA, your personal data may be transferred outside the EEA in order to provide you with these services.

Where personal data is transferred outside the EEA, we implement appropriate safeguards to ensure that your data remains protected in accordance with GDPR requirements. These safeguards may include:

Standard Contractual Clauses (SCCs): Where applicable, we use SCCs approved by the European Commission to ensure that data transfers to countries outside the EEA are compliant with GDPR.
Adequacy Decisions: For certain countries, such as Switzerland or Canada, the European Commission has issued adequacy decisions, recognizing that these jurisdictions provide an equivalent level of data protection.
Binding Corporate Rules (BCRs): In certain circumstances, we may rely on Binding Corporate Rules to facilitate internal data transfers within our organization while ensuring compliance with GDPR.

Security

The transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our site; any such transmission is at your own risk.

We have put in place security measures to prevent your data from accidental, loss or disclosure. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential. You should choose a password it is not easy for someone to guess.

In the event of a data breach we will notify the Commissioner for Personal Data and you in the event that the breach results in any likelihood of loss or damage to you.

Data retention

We retain your personal data for no longer than necessary to fulfill the purposes for which it was collected, in compliance with the GDPR’s storage limitation principle. 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.
Nonetheless, the following retention periods apply to different categories of personal data:

Customer Transaction Data: We retain data related to transactions, contracts, and payments for a minimum of 5 years, in accordance with legal obligations (such as tax, accounting, and anti-money laundering laws).

Marketing Data: If we collect data for marketing purposes, we will retain it for 1 year, or until you withdraw your consent, whichever occurs first. You have the right to withdraw consent at any time.

Other Data: For any other personal data not covered by the above categories, we will retain it for no longer than necessary for the specific purpose for which it was collected.

Once the relevant retention period has expired, your personal data will either be deleted, anonymized, or pseudonymized, in line with our data retention policies.

Use of cookies

Our Website uses cookies. To view our Cookie Policy please click here. We use cookies to gather information about your computer for our services and to provide statistical information regarding the use of our Website. Such information will not identify you personally – it is statistical data about our visitors and their use of our Website. This statistical data does not identify any personal details whatsoever.

We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Website and the service that we provide to you.

All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Website. Where we work with advertisers on our Website, our advertisers may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on advertisements on our Website.

Your rights

The GDPR gives you a range of rights in relation to the personal data that we collect from. You have the right to:

Access your personal data. This right is commonly known as the ‘data subject access request’ and enables you to receive a copy of the personal data we hold about you. You will not need to pay a fee to access your personal data unless we can justifiably demonstrate that the request is repetitive or excessive. We will respond to all legitimate data access requests within one month, but we may need to obtain further information from you in order to confirm your identity and the legitimacy of the request.
Request update of the personal data. This enables you to have any incomplete or inaccurate data corrected.
Erasure of your personal data. This enables you to ask us to delete personal data where there is no justifiable reason for us continuing to retain and process it. We may not always be able to delete the data such as if there is an ongoing contractual relationship between us or if we are legally required to retain the data.
Object to processing of your personal data where we are relying on consent or our legitimate interests (or those of a third party) as the justification for processing the data.
Restrict the processing of your personal data. This enables you to ask us to change the processing of your personal data. For example, you may wish to vary the basis on which we contact you.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, machine-readable format.
Withdraw consent. Where we are relying on consent to process your personal data you may withdraw that consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise these rights at any time by contacting our DPO at the contact details listed above.

Third-party links

You might find links to third-party websites on our website. If you click a link to a third-party website and visit that site, you may be allowing that site to collect and share certain data about you. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Complaints

If you wish to raise a complaint regarding our use of your personal data then you can contact the Commissioner for Personal Data , which is the supervisory authority for data protection issues in the Republic of Cyprus. (http://www.dataprotection.gov.cy).

If you do wish to raise a complaint then we would welcome the opportunity to discuss your concerns before you contact the Personal Data Commissioner to see if we can resolve the issue for you.

Changes to this policy

We may update these policies to reflect changes to the website and customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data.

We welcome any queries, comments or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us.

Version: July 2025