Privacy Notice

Introduction

Placy Ltd operates: (i) the website placy.ai (the Website); and (ii) an AI tool which is designed to allow users to search for properties for sale and rent via WhatsApp and Telegram (the AI Tool). The Website and AI Tool are collectively referred to as the Services.  

When you use our Services, you’re trusting us with your information. We understand this is a responsibility and we work hard to protect your information and put you in control. Please read the Privacy Notice below carefully which sets out how we process your personal data.

 

Privacy Commitment

We at Placy Ltd (we, our or us) respect your privacy and are strongly committed to keeping your information secure. This Privacy Notice describes our practices with respect to the personal data we collect from or about you when you use our Services. This Privacy Notice also describes your options as well as your rights regarding your personal data.

Placy Ltd is the controller of the personal data obtained via our Services, meaning that we are the organisation legally responsible for deciding how and for what purposes it is used.

If you have any questions or want more details about how we use Personal Information, you can contact us at  Charilaou Xyloforou 13, Agios Athanasios, 4103, Limassol, Cyprus or via email at dpo@placy.ai

By using our Services, you acknowledge that it is necessary for us to collect certain personal data about you in order to provide these Services to you.

 

What Personal Data We Collect and How

Basic contact and identification information: You provide us with your name and contact details such as email address and/or telephone number while you interact with our Services or while you complete our customer survey or provide us with feedback via email or through any other form of inquiry.

Search information: We collect the information that you include in the searches you input into the AI Tool. We also collect record telephone calls made to us or the AI Tool.  

Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

Social Media information: We have pages on social media. When you interact with those pages, we may collect personal data that you choose to provide us such as your contact details.

Other information you provide: We may collect other information that you may provide us while you interact with our Services such as your residential address.

Cookies and similar data collection technologies: These are collected automatically from your interactions with our website. When accessing our website, we collect data based on each access to the server. We use tracking technologies such as cookies to collect informationabout the way you interact with our website. This may include the browser types and versions used; the operating system used for access; the time and date of an access; the pages of the website that you visit; referrer URL; the IP address of your device; and what items were clicked on a page.

 

How We Use the Personal Data and On Which Legal Bases

Under data protection law, we (and all controllers) are only permitted to process personal data for a specific purpose if we have a lawful basis for that purpose. We have set out below the purposes for which we process your personaldata and the appliable lawful basis.

Purpose Lawful
To provide you with our Services, including administering and maintaining our Services and providing you with responses to your searches through our AI Tool. Necessary for the performance of the contract we have with you.
To respond to communications and queries you have raised with us whether via phone, email or otherwise. Our legitimate interests so that we can answer your queries
To record telephone conversations for training and improvement purposes whether made to us directly or calls with our AI Tool. Our legitimate interests so that we can improve our Services
To analyse how you (and others) interact with our Services so that we can improve them, for instance, by monitoring and recording how and when systems are accessed and how data is uploaded in order to analyse performance. This also allows our AI Tool to continually ‘learn and improve’. Our legitimate interests so that we can ensure that our Services are operating as effectively as possible
To analyse and understand your preferences so that we can offer you customised content and other personalisation to make the Services more relevant to your interests. Our legitimate interests to make the content that you receive more relevant to you and your needs
To send you news/updates for our products and Services. Consent
To send you direct marketing, including promotions and invitations on new or existing products and services including bonus guides. Consent
To develop new programs, products and services. Our legitimate interests so that we can create new offerings
To identify any misuse of our Services and protect the IT systems, architecture and networks. Necessary for the performance of the contact we have with you
To identify and prevent fraud or other criminal activity. Necessary to comply with our legal obligations
To report any fraud or other criminal activity to law enforcement and/or respond to queries from law enforcement. Necessary to comply with our legal obligations; or in our legitimate interests to ensure our Services are safe where notification is not required but proportionate
In accordance with legal obligations imposed upon us. Necessary to comply with our legal obligations
To defend ourselves legally. Necessary for the performance of the contract we have with you / necessary to comply with our legal obligations

We may also process your personal data for purposes which compatible with those listed above. Where we intend to introduce any new processing purpose we will update the table above.

 

Automated Decision-Making

Our AI Tool is automated, but we do not deploy automated decision-making, including profiling, via our AI Tool which could produce legal or similarly significant effects for you.  The AI Tool is intended to help provide you with useful information about properties in your area to aid your property search.

 

Disclosure of Personal Data

In certain circumstances, we may disclose your personal data to:

Processors (such as vendors and service providers): We use processors to assist us in meeting business operations needs and to perform certain services and functions. We may disclose personal data to processors, including providers of hosting services, customer service vendors, cloud services, content delivery services, data warehouse services, support and safety monitoring services,email communication software, web analytics services, payment and transaction providers, and other information technology services providers. These organisations are contractually obligated only to process your personal data inaccordance with our instructions.  Any processing by our processors will be consistent with this Privacy Notice.    

Business Transfers: We may disclose your personal data as part of a corporate transaction, including a purchase of allor part of our business, investment, reorganization, bankruptcy, receivership, or transition of service to another provider. Your personal data and other information may be disclosed in the diligence process with counterparties and others involved in such corporate transaction and may be transferred to a successor or affiliate as part of any completed transaction along with other assets.

Government Authorities or other third parties: We may share your personal data, including information about your interaction with our Services, with government authorities, industry peers, or other third parties in compliance with the law (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public; or (vi) to protect against legal liability.

Affiliates: We may disclose personal data to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Placy Ltd. Our affiliates may use the personal data we share in a manner consistent with this Privacy Notice.

Third parties: We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information, such as to receive marketing from such third party.

 

How Long Do We Keep Your Data

We will retain your personal data for only as long as we need in order to provide our Services to you, for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. It shall be deleted when it no longer serves the purpose for processing or shall be anonymized and therefore will no longer constitute personal data.

How long we retain personal data willdepend on a number of factors, such as:

  • our purpose for processing thedata (such as whether we need to retain the data to provide our Services);
  • the amount, nature, and sensitivity of the data;
  • the potential risk of harm from unauthorised use or disclosure of the data; and
  • any legal requirements that we are subject to.

 

Your Rights

You have the following statutory rights inrelation to your personal data:

  • Right to access: You have the right to request access to the personal data we hold about you.
  • Right to erasure (also known asthe right to be forgotten): You have the right to request that we delete your personal data in certain situations.
  • Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
  • Right to restrict processing: You have the right to request us to restrict the processing of your personal data in certain circumstances.
  • Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to a third party.
  • Right not to be subject to automated decision-making: You have the right to object to decisions based solely on automated processing, including profiling, that significantly affect you.
  • Right of objection: You have the right to object to any processing that is undertaken in respect of our legitimate interests.  
  • Right to withdraw consent: You have the right to withdraw your consent at any time if we rely on consent as the legal basis for processing your personal data.
  • Right to object to direct marketing: You have the right to object to our processing of your personal data for direct marketing purposes. You can exercise this right by contacting us at dpo@placy.ai or using the “unsubscribe” link in emails.

We thought it would be useful to providesome examples about how your rights in respect of data protection work as we appreciate many are not familiar with data subject rights. For example, if you would prefer that our AI Tool does not ‘learn’ from your interactions, which is something that we do on the basis of our legitimate interests, you can ‘object’ to this via the email below and we will cease this type of processing.  Or, if you would like us to delete information held about you for the purposes of personalising and customising response to you, you can do this by requesting erasure of this data, again by writing to the email below.  

To exercise any of your rights, please contact us at dpo@placy.ai.  When contacting us, please provide enough information to identify yourself and let us know which right(s) you want to exercise and the information to which your request relates.

Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent beforeit was withdrawn.

Please note that these rights are not absolute (save for objecting to direct marketing) and may be limited in certain circumstances, such as when fulfilling your request would reveal personal data about another person or if we are required by law or have compelling legitimate interests to continue processing your information.

Please note that exercising some of these rights may impact our ability to provide our Services to you. We will inform you of any such impact when you make a request to exercise your rights.

You also have the right to complain to your local supervisory authority, although we ask that you raise any concerns withus in the first instance. Further information is provided below.

 

International Transfers

Your personal data may be processed outside of the European Economic Area (EEA) where our affiliates, partners, merchants,or service providers may be located.

When we transfer your personal data, wewill do so pursuant to applicable data protection laws. To transfer your personaldata to other jurisdictions, we rely on the European Commission’s adequacy decisions on certain countries and, for other jurisdictions, we rely on the Standard Contractual Clauses as approved by the European Commission.

 

Security of Your Personal Data

We have appropriate security measures to prevent personal data from being accidentally lost, used, or accessed unlawfully, using encryption methods. We will notify you and any applicable regulator of any data breach that is likely to cause risk to you.

 

Children

Our Services are not directed to, orintended for, children under 13. We do not knowingly collect personal data from children under 13. If you are aware that a child's personal data has been shared with our website, please let us know so we can investigate and delete that data where applicable.

 

Cookies

We use cookies to run our website. A “cookie” is a small file containing a string of characters that is sent to your web browser and uniquely identifies your browser. Cookies help us collect information so we can better understand how you access and navigate our website. This information helps us develop and improve the design, layout, content, and function of our website. It also allows us to prevent fraud and improve our security.

We may also use cookies to track activity and click-through behaviour to better understand your preferences and browsing habits and to provide a more personalized experience while visiting our website and for more personalized alerts. We use different types of cookies to run the website. You can view and manage cookies in your browser.

You can be directed to our Cookies Policy for more information.

 

How to Contact Us

If you have any questions about our Privacy Notice, the data we hold about you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at dpo@placy.ai.

You may also find it helpful to refer to the guidance from the Data Protection Commissioner: https://www.dataprotection.gov.cy.

 

How You Can Complain to the Appropriate Authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you can complain to your local supervisory authority. For those based in Cyprus, please contact the Office of the Commissioner for Personal Data Protection at https://www.dataprotection.gov.cy.

 

Changes to This Privacy Notice

We may update this Privacy Notice from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law.

When you use Placy, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This Privacy Policy describes Personal Data (“Personal Data” or “data” or “information”) we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this as it highlights information about our privacy practices.

Issue Date: 21 February 2025