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Privacy Policy

Effective date: 14 June 2025

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1. Who We Are

AYA Urban Ventures Ltd. (“AYA,” “we,” “our,” or “us”) is a boutique real-estate advisory registered in Cyprus.

AYA Urban Ventures is the data controller for personal data collected through this website and related services.

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2. Scope

This Policy explains how we collect, use, share, and protect personal data when you:

  1. visit or interact with aya-urban.com (the “Site”);

  2. communicate with us via email, phone, or social media; or

  3. engage our advisory or investment-matching services.

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3. Personal Data We Collect

Category Examples How We Collect

Identification & Contact name, email, phone, postal address, company, job title web forms, event registrations, emails, calls

Investment Preferences asset class, budget, risk tolerance onboarding questionnaires, calls

TechnicalIP address, browser type, device ID, pages visited, time on page cookies, log files, analytics scripts

Marketing Engagement newsletter opens, link clicks email-marketing platform

Compliance & Verification passport copy, proof of funds, AML/KYC data secure upload or encrypted email when you progress in a deal

We do not intentionally collect data from children under 16.

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4. Legal Bases for Processing (GDPR, Cyprus Law 125(I)/2018)

Purpose Legal Basis

Responding to enquiries, delivering advisory services Contract performance (Art. 6 (1)(b))

Sending newsletters or event invitationsConsent (Art. 6 (1)(a))

Maintaining client files, AML/KYC checksLegal obligation (Art. 6 (1)(c))

Website analytics, improving UX, protecting against fraudLegitimate interests (Art. 6 (1)(f))

Where legitimate interest is used, we balance our interests against your rights and expectations.

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5. How We Use Personal Data

  • Provide and personalise our services

  • Match investors with appropriate real-estate opportunities

  • Send market updates, invitations, or promotional content you have opted into

  • Conduct due-diligence, AML/KYC, and regulatory reporting

  • Analyse website traffic and improve functionality

  • Enforce our Terms and protect the security of our systems

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6. Sharing & Disclosure

We share data only when necessary and under confidentiality clauses with:

  1. Service providers – web-hosting, email-delivery, CRM, analytics, cloud storage

  2. Professional advisers – lawyers, auditors, tax consultants

  3. Deal counterparties & partners – strictly when required to advance a transaction and only with your authorisation

  4. Regulators or law-enforcement – when required by law or court order

We never sell your personal data.

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7. International Transfers

Some providers operate outside the European Economic Area. Where this occurs, we rely on:

  • Adequacy decisions (e.g., the EU-US Data Privacy Framework), or

  • EU Standard Contractual Clauses (SCCs) with supplementary safeguards.

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8. Data Retention

  • Prospect enquiries: 24 months after last interaction unless you become a client or request deletion sooner.

  • Client files & AML/KYC: 7 years after the end of the business relationship (statutory requirement).

  • Analytics logs: 26 months.

When retention ends, data are securely deleted or anonymised.

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9. Security Measures

  • TLS encryption across the Site

  • Access-controlled cloud storage and 2-factor authentication

  • Regular penetration tests and vulnerability scans

  • Staff training on data protection and phishing awareness

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10. Your Rights (GDPR Articles 15–22)

You may, at no cost:

  1. Access the personal data we hold about you

  2. Rectify inaccurate or incomplete data

  3. Erase data (“right to be forgotten”) in certain cases

  4. Restrict or object to processing

  5. Port data to another provider

  6. Withdraw consent at any time (newsletters, cookies, etc.)

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To exercise your rights, email Access@aya-urban.com. We respond within 1 month.

If you believe we have infringed your rights, you may complain to the Office of the Commissioner for Personal Data Protection, 1 Iasonos St., 1082 Nicosia (www.dataprotection.gov.cy).

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11. Cookies & Similar Technologies

We use:

  • Essential cookies – site security and basic functions

  • Analytics cookies – Google Analytics (IP anonymization enabled)

  • Preference cookies – remember language or region

On your first visit, a banner lets you accept, reject, or customize cookies. You can change preferences anytime via the “Cookie Settings” link in the footer or through your browser controls.

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12. Third-Party Links

Our Site may link to external sites we do not control. We are not responsible for their privacy practices. Review their policies before providing personal data.

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13. Changes to This Policy

We may update this Policy to reflect legal, technical, or business developments. Material changes will be highlighted on this page and, where appropriate, notified by email. Re-visiting the Site after an update signifies acceptance.

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14. Contact Us

For questions, requests, or feedback about this Policy:

  • Email: Access@aya-urban.com

  • Phone: +357 977 432 67

  • Postal: AYA Urban Ventures Ltd., 151 Ledras St., Office 103, 1010 Nicosia, Cyprus

Last reviewed: 14 June 2025

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