Privacy Policy

1. Who We Are

Groundz Property Development Ltd ("Groundz", "we", "us") is a real estate development and investment company registered in Cyprus (Registration No. HE XXXXXX), with its registered office at [Address], Limassol, Cyprus.

We operate the website groundz.estate and the Groundz investor portal (collectively the "Platform"). Groundz is the data controller responsible for your personal data.

Contact our Data Protection Officer at: privacy@groundz.estate

2. Data We Collect

2.1 Data you provide directly

• Account data — name, email address, password (hashed), and role when you register
• Investor application — nationality, investor type, ticket size, time horizon, and investment preferences
• KYC documents — passport/ID copies, proof of funds, and other compliance documents required under Cyprus AML regulations
• Lead forms — contact details submitted through enquiry, brochure request, call booking, or quiz forms
• Correspondence — messages sent to us via contact forms or email

2.2 Data collected automatically

• IP address and browser/device information for security and fraud prevention
• Session cookies required for authentication (httpOnly, not used for advertising)
• Basic usage logs for platform stability and debugging

3. How We Use Your Data

We do not sell your personal data. We do not use your data for automated profiling that produces legal effects.

4. Data Sharing

We may share your data with:

• Service providers — cloud hosting (servers within the EU/EEA), email delivery, payment processors — under data processing agreements
• Legal and regulatory authorities — where required by Cyprus law, including the Cyprus Securities and Exchange Commission (CySEC) and MOKAS (Financial Intelligence Unit)
• Professional advisors — lawyers and auditors bound by professional confidentiality

We do not transfer your data outside the EU/EEA without adequate safeguards (Standard Contractual Clauses where applicable).

5. Data Retention

• Account data — retained for the duration of your account plus 5 years after closure
• KYC documents — retained for 5 years after the end of the business relationship, as required by Cyprus AML legislation
• Lead form data — retained for 2 years unless you convert to a registered user
• Security logs — retained for 90 days

6. Your Rights (GDPR)

Under the General Data Protection Regulation (EU 2016/679) and Cyprus Law 125(I)/2018, you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — request correction of inaccurate data
• Erasure — request deletion, where no overriding legal obligation requires retention
• Restriction — request that we limit processing in certain circumstances
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interests
• Withdraw consent — at any time, without affecting the lawfulness of prior processing

To exercise any right, email privacy@groundz.estate. We will respond within 30 days. You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus): dataprotection.gov.cy.

7. Cookies

We use only strictly necessary cookies for authentication and session security. No advertising or tracking cookies are set. You may disable cookies in your browser settings, but this will prevent you from logging in to the platform.

8. Security

We implement technical and organisational measures appropriate to the risk, including password hashing, HTTPS encryption in transit, and access controls. No internet transmission is 100% secure; we encourage use of a strong, unique password for your account.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified to registered users by email. The "Last updated" date at the top of this page reflects the most recent revision.