Privacy

Overview

This is a static website. It carries no contact form, sets no cookies of its own and embeds no analytics or advertising services. No profile of you is built here.

Personal data arises in three places: in our host's technical logs when the page is requested, when you book a call, and when you write or call us of your own accord.

Controller

The controller for data processing on this website is the provider named in the legal notice; the postal address and registration number are given there. For privacy enquiries you can reach us at contact@upcyprushomes.com.

Hosting and server logs

The site is hosted by an external service provider: bunny.net (BunnyWay d.o.o., Slowenien). When the page is requested, that provider's server automatically collects the following data transmitted by your browser: These logs serve secure and stable operation; they are not combined with other data sources.

The legal basis is our legitimate interest in a technically faultless presentation (Art. 6(1)(f) GDPR).

• IP address of the requesting device
• date and time of the request
• the address requested and the volume of data transferred
• browser type and operating system
• the previously visited page, where your browser transmits it

Cookies and browser storage

This website itself sets no cookies. No analytics tools, no audience measurement and no advertising networks are in use, and neither fonts nor maps are loaded from third-party servers. As soon as you reach the appointment step, the embedded Cal.com calendar sets three cookies of its own: one to protect against automated access (valid for 30 minutes) and two that secure the booking form against misuse (for the duration of your browser session only). They serve the security and operation of the calendar and are not intended to recognise you across websites. None of them is set before the calendar loads.

To operate, the site keeps a few entries in your browser's storage:

• the language you chose — kept
• your wishlist, meaning the properties you saved — kept
• the filters you last set on the property list — kept
• the reference number of the property you viewed last — for this visit only
• the language version you arrived from — for this visit only

Each of these entries is created only by an action of yours, none contains an identifier that makes you recognisable across websites, and none leaves your device — except for the details you deliberately send along with a booking. This storage is necessary for the functions you have called up and therefore requires no consent (Sec. 25(2) no. 2 TDDDG). A consent banner is thus unnecessary.

When you open the start page, the site also reads your browser's language setting in order to take you to the matching language version; if you have already chosen a language, that choice applies. Nothing is transmitted to us or to third parties in the process, and no profile is created. This reading, too, is necessary for the function you have called up and requires no consent (Sec. 25(2) no. 2 TDDDG).

You can delete these entries at any time in your browser settings.

When you contact us

If you email or call us, we process your details in order to handle your enquiry and any follow-up questions. The legal basis is Art. 6(1)(b) GDPR for pre-contractual steps, otherwise our legitimate interest in responding (Art. 6(1)(f) GDPR).

We erase this data once the matter is concluded, unless statutory retention periods require otherwise.

WhatsApp

The site links to WhatsApp. Only when you click that link does your device connect to WhatsApp; nothing is transmitted there beforehand.

The link brings along a prepared text that matches the page you clicked on — on a property page, its number and name, for example. You see this text in WhatsApp before you send it, and you can change or delete it.

If you write to us there, we process your phone number, the profile name you hold on WhatsApp and the content of your messages in order to answer your enquiry. The legal basis is Art. 6(1)(b) GDPR for pre-contractual steps, otherwise our legitimate interest in replying (Art. 6(1)(f) GDPR). The channel is your choice: we only write to you there if you have written to us first, and we send no marketing over WhatsApp.

We use the WhatsApp Business App on a company device. For users in the European Economic Area the service is operated by WhatsApp Ireland Limited (Merrion Road, Dublin 4, Ireland), part of the Meta group of companies, and a transfer to the United States is possible. Message content is end-to-end encrypted; connection data such as phone number and time are nonetheless processed by the operator, which is itself responsible for that processing. Details are set out in its privacy policy: https://www.whatsapp.com/legal/privacy-policy-eea.

We delete the message history once your enquiry is complete, unless statutory retention periods require otherwise.

You can reach us just as well by email or through the appointment booking — WhatsApp is not required.

Booking a call

To book a call we use Cal.com (Cal.com, Inc., 2261 Market Street #4382, San Francisco, CA 94114, United States). The calendar is embedded in our own page; it loads only once you have answered the three questions and reach the appointment step.

The following details are transmitted to Cal.com with your booking:

• first and last name
• email address
• telephone number
• your notes and any guests you invite, where you provide them
• your three answers from the questions: plan, budget and timing
• the reference number of the property in question, if you leave it attached
• the reference numbers of the properties on your wishlist, if you attach them
• the topic: the kind of page you booked from and which call to action took you there — “a specific property, question left open” or “wishlist, clarity on prices”, for example. It is a category and not a click path: we do not record which pages you visited, only what the call should be about
• a referral code, if you arrived through a partner link

You see the pre-filled entries before booking; you can deselect the property and the wishlist there.

What we use them for: a call about a property in Northern Cyprus only helps if we know beforehand what it is about. If the booking shows you came from a particular property, we prepare its documents, prices and purchase costs; if you come from your wishlist, we compare those properties; if your questions are general, we take the time to walk you through how a purchase works. Without these details the call starts by asking for them — that costs you time and gains you nothing.

The legal basis is Art. 6(1)(b) GDPR — the processing happens at your request and serves pre-contractual steps.

Cal.com processes this data on our behalf as a processor under a contract pursuant to Art. 28 GDPR. The company is based in the United States and processes the data there; individual subprocessors process it in further countries. The transfer is safeguarded by Standard Contractual Clauses or the EU-US Data Privacy Framework. Its representative in the European Union under Art. 27 GDPR is Felix Kolodziej, felix@cal.com. The details are set out in Cal.com's privacy policy: https://cal.com/privacy.

We erase your details once the call is concluded and no further cooperation follows from it, unless statutory retention periods require otherwise.

Passing on your enquiry

When you book an appointment or write to us, your enquiry first comes to us. We look at it and decide whether to pass it on to our partner agency on the ground — an estate agency based in Northern Cyprus, which holds the conversation and sees the purchase through. Whether we pass an enquiry on is decided case by case.

What we pass on is what you have told us:

• your name and contact details
• your answers from the three questions: goal, budget and timing
• the property in question and the properties on your wishlist, if you attach them
• the topic of your enquiry and a referral code, if there is one
• anything else you write to us yourself

The legal basis is Art. 6(1)(b) GDPR: we pass it on at your request and for pre-contractual steps. Without doing so we could not deal with your enquiry — advice on the ground is exactly what you are asking for.

Northern Cyprus is not a country for which the European Commission has found an adequate level of data protection. The transfer is therefore based on Art. 49(1)(b) GDPR; it is necessary for the pre-contractual steps you have requested. We cannot guarantee a level of protection equivalent to European law there: your rights under the GDPR may not apply to the agency to the same extent, and enforcing them may be harder.

You decide: without your enquiry we pass nothing on. If you would rather we did not, write to us at contact@upcyprushomes.com instead — then we will first clarify what you would like to know.

We delete your details on our side once the matter is closed, unless statutory retention periods say otherwise.

Your rights

You have the following rights regarding your personal data:

• access to the data held about you
• rectification of inaccurate data
• erasure
• restriction of processing
• data portability
• withdrawal of consent with effect for the future

An informal message to contact@upcyprushomes.com is sufficient.

Where processing rests on a legitimate interest, you may object to it on grounds relating to your particular situation (Art. 21 GDPR).

Right to lodge a complaint

If you believe that the processing of your data infringes data protection law, you may lodge a complaint with a supervisory authority. The competent authority is the one for your habitual residence, your place of work, or the place of the alleged infringement.

Changes to this policy

We update this policy whenever the legal position or the technology used on this website changes. The version available here is the one that applies.