Last Updated: 16 September 2025
1. Introduction
Novel Development Ltd (“we,” “us,” “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website https://www.novel-development.eu (the “Site”) or interact with us.
We are registered in the Republic of Cyprus under company registration number [Insert Your Company Registration Number] with our registered office at 1 Alexandrou Panagouli, 6057, Larnaca, Cyprus.
This policy is prepared in accordance with the EU General Data Protection Regulation (GDPR) 2016/679 and the Cypriot Law 125(I)/2018 on the Protection of Natural Persons with regard to the Processing of Personal Data.
2. Data Controller
The data controller responsible for your personal data is Novel Development Ltd. For any questions about this policy or our privacy practices, please contact us at:
Email: info@novel-development.eu
Address: 1 Alexandrou Panagouli, 6057, Larnaca, Cyprus
3. Information We Collect
We may collect and process the following categories of personal data:
Personal Identifiers: Name, surname, title.
Contact Data: Email address, telephone number, physical address.
Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system, and other technology on the devices you use to access our Site. This is collected via cookies and similar technologies.
Usage Data: Information about how you use our Site, including the pages you view, the properties you click on, and the links you follow.
Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
Inquiry Data: Any information you provide when you contact us via forms, email, phone, or in person regarding our properties or services.
Property Preference Data: Your search criteria, desired location, budget, and other preferences related to real estate.
4. How We Collect Your Data
Direct Interactions: You may give us your data by filling in forms on our Site, by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
– Inquire about or express interest in a property.
– Subscribe to our newsletter or marketing materials.
– Request information to be sent to you.
Automated Technologies or Interactions: As you interact with our Site, we may automatically collect Technical and Usage Data through cookies, server logs, and other similar technologies.
Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties, such as:
– Analytics providers (e.g., Google Analytics) based outside the EU.
– Social media platforms (e.g., Facebook, Instagram) if you interact with our profiles.
5. Legal Basis for Processing (GDPR Compliant)
We will only process your personal data when we have a lawful basis to do so. Our lawful bases include:
Consent: For sending you marketing communications and newsletters. You can withdraw your consent at any time.
Contractual Necessity: To take steps at your request prior to entering into a contract (e.g., to provide you with information about a property you inquired about) or to perform a contract with you.
Legitimate Interests: For operating and improving our Site, for fraud prevention, and for administrative purposes, provided your interests and fundamental rights do not override those interests.
Legal Obligation: Where we need to comply with a legal or regulatory obligation in Cyprus.
6. How We Use Your Data
We use your personal data to:
– Present our Site and its contents to you.
– Provide you with information, properties, or services that you request from us.
– Manage our relationship with you, including notifying you about changes to our terms or privacy policy.
– Send you marketing communications about properties, services, and events we think may be of interest to you (where you have consented).
– Administer and protect our business and this Site (including troubleshooting, data analysis, and system testing)
– Use data analytics to improve our Site, marketing, customer relationships, and experiences.
7. Data Sharing and Disclosures
We may share your personal data with the following parties for the purposes set out in this policy:
Service Providers: Trusted third parties who provide services on our behalf, such as IT and system administration services, marketing agencies, professional advisors (lawyers, accountants).
Business Partners: Carefully selected real estate agents and partners in Cyprus to help fulfill your requests.
Legal and Regulatory Authorities: If we are required to do so by law or in connection with legal proceedings.
Third Parties in case of Merger/Acquisition: In the event we sell or transfer all or a portion of our business or assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
8. International Transfers
We primarily store and process data within the European Economic Area (EEA). If we transfer your data outside the EEA (e.g., to US-based analytics providers), we will ensure a similar degree of protection is afforded by using specific contracts approved by the European Commission (Standard Contractual Clauses) or other legally accepted mechanisms.
9. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your personal data to those employees, agents, and contractors who have a business need to know.
10. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements in Cyprus. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data.
11. Your Data Protection Rights
Under GDPR and Cypriot law, you have the right to:
– Access your personal data.
– Rectify inaccurate or incomplete data we hold about you.
– Erase your personal data (the “right to be forgotten”).
– Restrict the processing of your data.
– Data portability – to receive your data in a structured, machine-readable format.
– Object to processing based on legitimate interests or for direct marketing.
– Withdraw consent at any time, where we rely on consent to process your data.
To exercise any of these rights, please contact us using the details in Section 2.
You also have the right to lodge a complaint with the Cypriot supervisory authority: The Office of the Commissioner for Personal Data Protection (1 Iasonos Street, 1082 Nicosia, Cyprus | commissioner@dataprotection.gov.cy | +357 22818456).
12. Cookies
Our Site uses cookies to distinguish you from other users. This helps us provide you with a good experience and allows us to improve our Site. For detailed information on the cookies we use and their purposes, please see our Cookie Policy [Link to your separate Cookie Policy].
13. Changes to This Privacy Policy
We may update this policy from time to time. The updated version will be indicated by an updated “Last Updated” date at the top of this page. We encourage you to review this policy periodically.