Privacy Policy

RealtyHub Privacy Policy

Effective Date: 16^th of December 2025

1. Introduction

This Privacy Policy explains how RealtyHub (the “Platform”), operated by RimaTech Ltd (HE 439114, Republic of Cyprus), collects, uses, stores, and protects your personal data when you use our services.

We are committed to protecting your privacy and complying with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Cyprus Data Protection Law 125(I)/2018.

By using RealtyHub, you agree to this Privacy Policy. If you do not agree, you must stop using the Platform.

2. Data Controller

RimaTech Ltd

Bridge Tower, Alexandrias 2–4, Limassol 3013, Cyprus

📧privacy@rimatech.com.cy

📧dpo@rimatech.com.cy (Data Protection Officer)

3. Personal Data We Collect

We may collect and process the following categories of personal data when you use RealtyHub:

Registration Data: Name, email address, phone number, real estate licence details, and company affiliation.

Profile Information: Username, logo or profile picture, preferences, and account settings.

Property Listings: Descriptions, photos, floor plans, documents, and related metadata (including third-party data you upload).

Communications: Messages, enquiries, and support requests exchanged via the Platform.

Payment Information: Billing details, tax information, and transaction references (processed securely by third-party payment processors).

Usage Data: IP address, browser type, device identifiers, pages visited, access times, and general usage patterns.

Cookies: See Section 12 and our Cookies Policy.

Technical Logs & Security Data: RealtyHub automatically collects certain technical information to maintain platform security and performance, including IP address, browser type, session identifiers, and access timestamps.

This processing is carried out under RealtyHub’s legitimate interest in ensuring the integrity and security of its systems (Article 6(1)(f) GDPR) and is used solely for fraud prevention, debugging, and system maintenance.

Public Listing Identity Data:

When Users publish Listings, RealtyHub displays certain identity information to ensure transparency, including:

• Contact Name
• Contact Role
• Company Name (if linked)
• Company Type
• Real estate registration/license numbers (for licensed agents/agencies)

This information is processed under RealtyHub’s legitimate interest in providing a transparent and trustworthy MLS platform, and to enable Users and or general public to assess the origin of listings.

3.1 International Transfers

Your data may be transferred or stored outside the European Economic Area (EEA) in jurisdictions that provide an adequate level of protection as recognised under the GDPR.

Where such adequacy decisions do not exist, RealtyHub implements Standard Contractual Clauses or equivalent safeguards.

You may request a copy of these safeguards by contacting 📧privacy@realtyhub.cy.

3.2 Fraud Prevention & Compliance

RealtyHub may share limited personal data with regulatory authorities, law-enforcement bodies, or credit institutions where necessary to detect fraud, prevent abuse, or comply with legal obligations.

3.3 Unsolicited Communication

You may unsubscribe from promotional communications or report unwanted messages at any time by using the unsubscribe option included in our messages or by emailing 📧support@realtyhub.cy

3.4 Property Listing Related Inquiries via the Platform and Lead Management

When visitors or users submit inquiries through the Platform in relation to a property listing (for example, by using an “Ask a question”, “Contact”, or similar inquiry form), RealtyHub processes the personal data provided in the inquiry. This may include the sender’s name, email address, telephone number (if provided), message content, property or listing reference, timestamp, and technical metadata.

Such processing is carried out for the purposes of:

• transmitting the inquiry to the relevant User associated with the property listing or to other eligible Members of the Platform, where applicable;
• contacting the sender to verify or clarify the inquiry, confirm genuine interest, prevent misuse or spam, and improve the quality and relevance of inquiries;
• facilitating introductions between inquiry senders and Members as part of the Platform’s lead or inquiry services;
• operating, administering, securing, and auditing the Platform, including billing and dispute handling in connection with lead-based services.

Legal basis for processing:

Article 6(1)(b) GDPR — processing is necessary to take steps at the request of the data subject prior to entering into a potential contractual relationship; and

Article 6(1)(f) GDPR — processing is necessary for the legitimate interests of facilitating communication between marketplace participants, maintaining platform integrity, preventing abuse, improving matching efficiency, and operating the Platform’s commercial services.

Inquiry data may be shared only with relevant Member(s) of the Platform for the purposes described above. RealtyHub does not use inquiry data for direct marketing purposes unless a separate legal basis applies and does not disclose such data to unrelated third parties.

4. How We Collect Data

• Directly from you: when you register, upload Listings, or contact us.
• Automatically: through cookies, logs, and analytics.
• From third parties: service providers, public registers, or authorized partners.

5. Legal Basis for Processing

We process your personal data under GDPR on the following bases:

• Consent: e.g., for marketing communications.
• Contractual necessity: to provide access to the Platform and services.
• Legitimate interests: e.g., improving services, preventing fraud, analytics.
• Legal obligations: e.g., Cyprus tax, AML, or regulatory compliance.

6. How We Use Data

We may use your data to:

• Provide and manage your account.
• Enable you to create and manage Listings.
• Facilitate collaboration with other Members.
• Process payments and billing.
• Send service updates, invoices, and security alerts.
• Respond to enquiries and provide support.
• Send marketing communications (with your consent).
• Conduct analytics, market reports, and service improvements.
• Train AI systems and create aggregated insights, using anonymized data.
• Support future AI-driven services, including valuation models, image recognition, and property analytics.

6A. WhatsApp and Electronic Marketing Messages

If you opt-in to receive marketing or service updates via WhatsApp Business or similar channels, we will process your contact information (e.g., phone number, name) for that purpose based on your consent under Article 6(1)(a) GDPR.

You may withdraw consent at any time by replying “STOP” to the WhatsApp message, emailing 📧privacy@rimatech.com.cy, or adjusting your settings. Once you withdraw consent, we will cease sending WhatsApp communications except those strictly necessary for account or security purposes.

We maintain records of your opt-in and opt-out to demonstrate compliance with the WhatsApp Business Policy and GDPR.

All WhatsApp communications are subject to Meta Platforms’ Business Terms and Privacy Policy, and Meta acts as an independent data controller for its processing.

We do not engage in automated decision-making with legal or significant effects.

7. Export of Listings to Realty.com.cy and Third-Party Platforms

When you use the Export Function, your Listings and professional contact details are also published on Realty.com.cy or other third-party platforms.

• RealtyHub and each receiving platform act as independent data controllers. Each is responsible for its own processing activities under GDPR.
• Your data will also be processed under the privacy policy, terms, and payment rules of the receiving platform.
• You are solely responsible for reviewing, understanding, and consenting to the policies of Realty.com.cy (or any other third-party platform) before exporting your data.
• If you do not agree with the applicable terms or privacy policy of the third-party platform, you must not use the Export Function.

7A. Company Affiliations and Database

RealtyHub maintains a database of real estate agencies, developers, and related companies compiled from public registers, official sources, and publicly available information.

• Self-Declared Affiliations: When Users select a company from this database, it is a self-declaration. RealtyHub does not verify such affiliations. Users are solely responsible for the accuracy of their declared company link. False declarations constitute a breach of these Terms.
• Logos and Identifiers: Company names, license numbers, and logos are displayed for identification only. RealtyHub claims no ownership of these identifiers.
• These identifiers are displayed publicly only as part of the Listing Identity and are derived from User self-declarations. RealtyHub does not verify licensing, ownership, or authorization unless required by law.
• Correction or Removal: Companies may request correction or removal of their data from the RealtyHub database by contacting 📧privacy@rimatech.com.cy. We will review and act on such requests within a reasonable period.

8. Disclosure of Data

We may share your data with:

• Other Members: when you upload Listings or interact on the Platform.
• Service Providers: hosting, payments, analytics, customer support.
• Public users: when you export Listings to Realty.com.cy.
• Authorities: where required by law or to enforce our rights.
• Business Transfers: if RimaTech Ltd is acquired, merged, or restructured. You will be notified before any transfer of your personal data.

9. Aggregated & Anonymized Data

We may retain and use aggregated or anonymized MLS data (with no personal identifiers) for:

• Market reports and analytics.
• Research and development.
• AI training.
• Public communications and marketing.

Such data cannot identify you personally.

10. Data Retention

We retain personal data only as long as necessary for its purpose or as required by law. Examples:

• Account data: kept while the account is active.
• Listings: deleted when removed by the user, but anonymized or archived copies may be retained for compliance, analytics, and system integrity as long as needed.
• Billing records: retained for 7 years (per Cyprus tax law).

11. Your Rights

Under GDPR, you may:

• Access your data.
• Correct inaccurate data.
• Request deletion (“right to be forgotten”).
• Restrict processing.
• Port your data to another provider.
• Object to processing based on legitimate interest.
• Withdraw consent (e.g., marketing), you may object at any time to receiving marketing or promotional messages via WhatsApp, SMS, or email.

You may lodge a complaint with the Office of the Commissioner for Personal Data Protection (www.dataprotection.gov.cy).

To exercise your rights, contact 📧privacy@rimatech.com.cy.

12. Cookies

We use cookies and similar technologies to operate the Platform, analyze traffic, and improve services.

• Essential cookies: required for the Platform (no consent needed).
• Non-essential cookies (analytics, personalization, ads): require consent.
• Advertising cookies: not currently used. If introduced, we will obtain your consent first.

For full details, see our Cookies Policy.

13. Security

We implement industry-standard technical and organizational measures, including:

• Encryption in transit and at rest.
• Access controls and authentication.
• Regular monitoring and security reviews.

If a breach occurs that may affect your rights, we will notify you and the Cyprus Data Protection Commissioner, as required by GDPR.

14. Third-Party Links

Our Platform may link to third-party services. This Policy does not cover them. We recommend reviewing their privacy terms before use.

15. Children’s Data

The Platform is for professionals only and not directed at children under 18. If children’s data is discovered, we will delete it immediately and may suspend the account.

16. Changes

We may update this Policy from time to time. Updates take effect upon posting. If material changes affect your rights or obligations, we will notify you at least 30 days in advance by email or through the Platform.

17. Contact

For privacy questions or requests:

📧privacy@rimatech.com.cy

📧dpo@rimatech.com.cy