[REVIEW] This Privacy Policy is a starting draft. It must be reviewed by a qualified lawyer before the website is launched, and every [REVIEW] note must be completed or removed. It is written with India’s Digital Personal Data Protection Act 2023, the UK GDPR and EU GDPR (for visitors in the UK, Cyprus and Greece), the UAE Personal Data Protection Law and Thailand’s Personal Data Protection Act in mind, but it is not legal advice.
Last updated: [REVIEW: add date]
1. Who we are
This website, eylfarealty.com, is operated by Eylfa Realty, a real estate advisory business registered in India (“Eylfa Realty”, “we”, “us”). We are responsible for the personal information described in this policy.
[REVIEW] Add your full registered legal entity name, registration number and registered office address.
You can contact us about privacy at hello@eylfa.com.
2. Information we collect
Information you give us. When you send an enquiry through our website form, we collect your name, email address, and — if you choose to provide them — your phone or WhatsApp number, country of residence, destinations of interest, approximate budget, investment timeline, preferred contact method and your message. We also record the date and time you gave consent and the page you sent the form from.
When you contact us directly. If you email us or message us on WhatsApp, we receive the information you include, such as your name, number or email address and the content of your messages.
Technical information. Our hosting provider automatically records basic technical information, such as IP address, browser type and the pages requested, in server logs used for security and to keep the website running.
[REVIEW] Confirm with your hosting provider how long server logs are kept.
Cookies. We do not use analytics, advertising or tracking cookies. The website may set strictly necessary cookies, for example when an administrator logs in. If we add analytics or other non-essential cookies in future, we will update this policy and ask for your consent where the law requires it.
3. How we use your information
- To respond to your enquiry and discuss the services you are interested in.
- To provide our advisory services if you choose to work with us.
- To introduce you to licensed local partners, such as agents, lawyers or other professionals, where needed to help with your plans — only after discussing this with you.
- To keep records of our communications and meet our legal and regulatory obligations.
- To protect our website against spam, fraud and misuse.
We do not sell your personal information, and we do not use it for automated decision-making.
4. Legal basis
Depending on where you live, we rely on one or more of the following: your consent (for example, when you submit the enquiry form); the need to take steps at your request before entering into an agreement with you; our legitimate interests in running and protecting our business; and compliance with legal obligations. Where we rely on consent, you can withdraw it at any time.
5. Who we share it with
- Licensed local partners in the countries you are interested in, where needed to assist you and after discussing this with you.
- Service providers who help us run our business, such as our website hosting provider and our email provider. [REVIEW: name your hosting and email providers.]
- WhatsApp (Meta), if you choose to contact us on WhatsApp. Your use of WhatsApp is governed by WhatsApp’s own terms and privacy policy.
- Authorities or professional advisers, where required by law or to protect our legal rights.
6. International transfers
We are based in India and work with partners in the United Arab Emirates, Thailand, Cyprus, Greece and the United Kingdom. Your information may therefore be transferred to and processed in these and other countries. Where the law requires it, we put appropriate safeguards in place for these transfers.
[REVIEW] Confirm with your lawyer which safeguards apply (for example, standard contractual clauses for transfers of UK or EU personal data).
7. How long we keep it
We keep enquiry information for as long as needed to respond to you and for [REVIEW: e.g. 24 months] after our last contact, unless we need to keep it longer to meet legal obligations or because you become a client.
8. Your rights
Depending on where you live, you may have the right to access the personal information we hold about you, correct it, ask us to delete it, withdraw your consent, object to or restrict certain uses, and receive a copy in a portable format. To exercise any of these rights, contact us at hello@eylfa.com. We may need to verify your identity before responding.
You also have the right to complain to a data protection authority, such as the Data Protection Board of India, the UK Information Commissioner’s Office, the Commissioner for Personal Data Protection in Cyprus, the Hellenic Data Protection Authority in Greece, the UAE Data Office or Thailand’s Personal Data Protection Committee. We would appreciate the chance to resolve your concern first.
[REVIEW] India’s DPDP Act requires you to publish contact details of a person who can answer questions about personal data. Add the name or role and contact details of your grievance or privacy contact.
9. Security
We use reasonable technical and organisational measures to protect your information, including encrypted connections (HTTPS) and restricted access to enquiry records. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
10. Children
Our website and services are intended for adults. We do not knowingly collect personal information from anyone under 18.
11. Links to other websites
Our website may link to other websites, including WhatsApp. We are not responsible for the privacy practices of other websites.
12. Changes to this policy
We may update this policy from time to time. The “Last updated” date at the top shows when it was last changed.
13. Contact us
Questions about this policy or your personal information: hello@eylfa.com.