Introduction
Last updated: 26 September 2025
This Privacy Policy explains how we collect, use, and protect your personal data in accordance with the General Data Protection Regulation (GDPR) and the requirements of the Cyprus Data Protection Commissioner.
By using our website, contacting us, or engaging with our services, you acknowledge this notice. This statement does not constitute consent to processing.
1. Who We Are
Data Controller:
Flerie Properties Ltd
HE 420368
Michalakopoulou 27,
City Business Centre, Flat/Office FF18,
1075 Nicosia, Cyprus
Contact:
Email: [email protected]
Phone: +357 97 731133
Supervisory Authority: Office of the Commissioner for Personal Data Protection, Cyprus ([email protected])
About LUMA Developers
Operating under the brand LUMA Developers, we are a Cyprus-based property developer focused on delivering modern, energy-efficient homes in desirable locations. Our projects are designed for international investors, first-time buyers, and families relocating to Cyprus.
We are committed to transparency, professionalism, and high standards of data protection in every aspect of our business. Protecting your personal information is part of the trust we aim to build with every client.
2. Data We Collect
We may collect and process the following types of personal data:
– Contact details: name, email, phone number, message content.
– Property preferences: budget, type of property, investment purpose.
– Technical data: IP address, device/browser information, usage of our website.
– Marketing data: interactions with our advertising (Google Ads, Meta Ads), cookie preferences.
We do not intentionally collect special categories of data or information about children.
3. How We Collect Data
– Directly from you (forms, email, phone calls).
– Automatically through cookies and analytics when you use our website.
– From advertising platforms (Google Ads, Meta Ads) when you submit forms or interact with ads.
4. How We Use Your Data
We use your data only where permitted by law, including:
– To respond to enquiries and provide information about our properties.
– To manage client relationships and schedule viewings.
– To improve our website and services (analytics).
– To deliver marketing communications and remarketing campaigns (with your consent where required).
– To comply with legal and regulatory obligations.
We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects concerning you.
5. Legal Basis for Processing
We process your data based on:
– Your consent (e.g. marketing, newsletters).
– Performance of a contract or steps before entering into a contract (property enquiries, client services).
– Our legitimate interests (analytics, advertising, improving services).
– Compliance with legal obligations.
6. Sharing Your Data
We only share your personal data with trusted third parties, such as:
– Hosting and IT service providers.
– Advertising and analytics providers (Google, Meta).
– Professional advisers (legal, accounting) where required.
All third parties are contractually required to respect the confidentiality and security of your data. We do not sell your personal data.
7. International Transfers
Some providers (e.g. Google, Meta) may process data outside the European Economic Area (EEA).
Where this happens, we rely on GDPR-approved safeguards such as Standard Contractual Clauses (SCCs).
8. Data Retention
– Enquiries and leads: up to 12 months from last contact.
– Marketing data: until you opt out or withdraw consent.
– Legal/financial records: kept for the statutory period.
After retention periods, data are securely deleted or anonymised.
9. Your Rights
You have the right to:
– Access, correct or delete your data.
– Restrict or object to processing.
– Withdraw consent at any time (without affecting past lawful use).
– Request transfer of your data.
– Lodge a complaint with the Cyprus Data Protection Commissioner.
To exercise these rights, contact us at [email protected].
10. Cookies & Tracking
We use cookies and pixels to:
– Enable website functionality.
– Analyse traffic and improve performance.
– Deliver personalised advertising (remarketing).
You can manage cookies in your browser settings. For more details, see our Cookie Policy.
11. Security
We apply strong technical and organisational measures to protect your personal data against loss, misuse, unauthorised access, or disclosure. Access is restricted only to authorised personnel and carefully selected service providers.
12. Updates to This Policy
We may update this Privacy Policy from time to time. Updates will be posted on this page with a new “Last updated” date.
