Last updated May 25, 2018

This privacy document (Privacy Policy, Agreement) describes how APL Alexander Real Estate Ltd and/or its affiliates (hereinafter referred to as the Company) handle personal information and protect your privacy. The Company acts as the controller (hereinafter referred to as the controller) of your data, which is described in more detail in the section "Organizations collecting personal data" of this document" and the processes of data processing and protection on the websites https://www.apl-home.com , https://www.apl-home.com .

This Agreement may be amended or supplemented at the discretion of the Company and the Site Administration at any time by sending you a special notice of this by e-mail or other means. However, we recommend that visitors and users of our sites regularly review the Privacy Policy.

The terms of this Privacy Policy in its current version apply to all personal (private) information received and stored by us, which is defined as any information identifying an individual or determining their location. Personal data means any information related to an individual identified or identifiable on the basis of such information. In this regard, the Company has done everything possible to ensure that you have easy and unlimited access to information about the privacy policy and can resolve the issue of its compliance and the use of your data at any time. The policy regarding the processing of personal data by the Company is presented on all pages of the site in the footer and is available at the link https://www.apl-home.com/privacy-policy/ .

To update your personal information and settings, please see the section "Accessing your personal information, updating, deleting information, and changing your privacy settings."

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data (hereinafter referred to as GDPR), the Company undertakes to fulfill its obligation to maintain confidentiality with regard to personal data, to comply with EU regulations and legislation on the receipt, processing and protection of data. For these purposes, the Company will take the necessary measures to ensure the security of the personal data received and to protect it from unauthorized access.

 

 

Privacy Protection Basics

The Company supports the EU General Data Protection Regulation (GDPR) 2016/679 of the European Parliament and of the Council. The Company makes every effort to treat all personal data received from European Union (EU) member states in accordance with the applicable Privacy Shield principles. For more information about the Privacy Shield, please refer to the EU and EU privacy and data protection rules and regulations drawn up by the European Commission https://ec.europa.eu/info/law/law-topic/data-protection_en .

The Company is responsible for the processing of personal data received in accordance with the GDPR and transfers these obligations to any third party agents acting on its behalf. The Company complies with the Privacy Shield Principles in relation to any onward transfer of personal data from the EU, including in relation to the onward transfer of obligations.

The subjects whose personal data are processed in the Company with or without the use of automation tools are:

· users and subscribers of the Company’s website on the Internet;

· employees of the Company or persons who had employment relationships with the company, as well as members of their families;

· persons who have civil-law contractual relations with the Company, or who are at the stage of pre-contractual or completed relations of a similar nature;

· partners and participants of the Company;

· the Company’s counterparties, represented by individual entrepreneurs, their employees; founders, managers, representatives (persons acting on the basis of powers of attorney) and employees of legal entities that have or have had contractual relations with the Company, or wish to conclude contracts with the Operator;

· visitors to the Company’s offices;

· other persons whose personal data processing is necessary for the Company to achieve the purposes specified in this Policy.

When we say "you", "your", "yourself" or "yourself", we mean to address the subject.

With respect to personal data received or transferred in accordance with the GDPR, the Company is subject to the enforcement powers of the European Commission. In certain situations, the Company may be required to disclose personal data as a result of a lawful request received from public authorities, including to meet requirements related to national security and law enforcement.

If you have any concerns about privacy or data use that we have not been able to resolve satisfactorily, you may contact the Company's designated Privacy and Data Protection Officer, details of whom are provided in the section "Company's Data Protection Officer". Once the dispute resolution procedure with the Company's designated officer has been exhausted, you may resort to binding arbitration or contact the relevant user data protection authorities. Official information on the EU national data protection authorities is available here: https://ec.europa.eu/commission/sites/beta-political/files/national-data-protection-authorities-jan_2018_en.pdf .

 

Organization collecting personal data

This Agreement and the Privacy Policy are issued on behalf of APL Alexander Real Estate Ltd and/or its affiliates. When we say “Company”, “data controller”, “we”, “our”, “us” or “us”, we mean the relevant organization responsible for processing your data. Which Company acts as your data controller is determined in the relevant terms of service or this Agreement. Personal data on this website is received by the Company:

"APL Alexander Real Estate Ltd"
HE316361

ADDRESS:

59 Amathoundos Ave., No. 3

4532 Limassol, Cyprus

Coordinates: 34.708241, 33.125329

PHONES:

Office: (+357) 25 43 10 18

Fax: (+357) 25 43 15 14

E-MAIL: info@apl-home.com , apl@apl-home.com

 

The company's authorized person responsible for data processing

The Company has appointed an authorized person (hereinafter referred to as DPO – data protection officer), responsible for compliance with the Privacy Policy, protection of personal data, communication on issues related to this privacy document. The authorized person is responsible for compliance with the Privacy Policy, control and management of personal data, systematic monitoring of data of individual users and persons responsible for compliance with the protection rules.

If you have any questions or concerns about this Agreement and the Privacy Policy, how we manage your personal data, or if you have any other concerns regarding personal information, please contact our Data Protection Officer at apl@apl-home.com .

 

Categories of personal data collection and information processed

You can perform some operations on the site without providing personal information.

However, when you register, leave data to use the Company's website and other products or services and become a subscriber to the site so that we can provide you with services, we may receive the following personal information from you:

· contact information (your name, telephone number, email address);

Depending on the operations performed, some of the requested information is mandatory to provide, and some is provided at your discretion. If you do not provide the mandatory information, you will not be able to perform the corresponding operations and interact with the site to the fullest extent.

Like most corporate websites, the Company and its third-party service providers may receive certain technical and routing information about your computer as you use the website to make it easier for you to use the website and its services. For example, we may record environmental variables such as your browser type, operating system, processor speed, and IP address. We use these environmental variables to track your use of the site and its services and to make them more convenient. The Company also uses these environmental variables to track traffic on the site. We may occasionally combine this data with your personal information to better understand the needs of site visitors.

In order to reduce errors in our database, verify the authenticity of users and prevent misuse of the system, we may from time to time supplement the personal information you provide with information from third party public sources. We may supplement the information we receive directly from you with information held in third party databases, such as demographic or company data, to increase the likelihood that any marketing communications we send you will be useful and interesting to you. A list of third party ancillary processors we may use is set out in this document.

When you download and use our mobile applications or services, we automatically receive information about the type of device you use, as well as the operating system version.

The Company may collect and use information about the geographic location of your computer or mobile device. The purpose of collecting this data is to provide you with information about services in your area that may be of interest to you and to improve the products and services offered there.

 

 

Purposes of obtaining and storing data

All personal data received by the Company is necessary for us to better understand your needs when interacting with the site, improve technical characteristics and marketing activities for your convenient use of the site.

We receive personal information and use environmental variables to track your use of the site and its services and to make them more convenient. The company also uses such environmental variables to track traffic on the site. We may occasionally match this data with your personal information to better understand the needs of site visitors.

 

How your personal information is used

The Company obtains your personal information to provide you with services, to comply with our legal obligations, and to improve our products and services. We do not sell, rent, or provide your personally identifiable information to third parties in any way other than as described in this Privacy Policy. The Company may use this information for the following purposes:

· responding to requests to the Company received from users when interacting with the website;

· send you requested information about products or services;

· responding to requests and complaints sent to the support service;

· informing you about special offers and services of the Company and selected third parties;

· manage advertising campaigns in which you participate by accepting this Agreement;

· investigate, prevent or take action against illegal activities and/or violations of the terms of service;

· conducting research and development of products/services to improve our website, offerings and services;

· satisfying your personal requests and preparing services and offers individually for you.

Information collected through cookies, logs, clear gifs and/or third party resources is used to create a database of your preferences. We link personally identifiable information and/or membership history to the information in this database to tailor advertising offers, improve site content and identify your interests.

In some cases, upon official request from authorized bodies, the Company is obliged to disclose your personal information in order to meet national security or law enforcement requirements.

In situations where it is required by law (for example, to comply with a subpoena, warrant, order or court decision against the Company), and when we believe that disclosure is necessary to protect our rights, avoid litigation, protect your safety or the safety of others, investigate fraud and/or respond to requests from government authorities. We may also disclose information about you if such disclosure is necessary in the interests of national security, law enforcement or other issues of public importance.

 

Sharing personal information with other organizations, service providers and agents

The Company engages certain support operators (including entities and third parties as listed below), subcontractors and content delivery networks that assist in maintaining the Site and providing the services described in the Service Agreement.

 

About auxiliary operators

An auxiliary processor is a third party (APL Alexander Real Estate Ltd and affiliated companies) engaged by the Company to process data that has or may have access to or the ability to process information of clients or users (including personal data). The Company undertakes to use a commercially reasonable due diligence process to assess the security and privacy practices of proposed auxiliary processors that will have or may have access to or the ability to process the Company's data.

The Company requires the subcontractors with whom it works to accept certain terms and conditions governing the use of information and personal data of subjects, including, without limitation, those obliging it to:

· process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data (GDPR);

· engage trustworthy employees who comply with contractual obligations to ensure confidentiality and data protection to the extent required by applicable data protection laws;

· regularly conduct training on security and data protection for employees who are granted access to personal data;

· implement and apply appropriate technical and organizational measures to ensure the security, integrity and confidentiality of the customer’s information and personal data;

· conduct annual certification confirming compliance with applicable data protection laws or permit the Company to audit such compliance;

· immediately inform the Company of any actual or potential incident related to security or data leakage;

· provide all reasonable assistance to the Company in dealing with requests from personal data operators, data subjects or data protection authorities, if any.

The information provided here is intended solely to illustrate the Company's interactions with subprocessors, and to provide an up-to-date list of third-party subprocessors engaged by the Company as of the effective date of this Privacy Policy (i.e. those that the Company may engage to provide the Services and ensure their functioning). If you have any questions about this notice or the Company's engagement of these subprocessors, please contact us at info@apl-home.com .

List of such third-party auxiliary operators:

1. Google.Analytics. You can find detailed information about the use of the system here: http://www.google.com/analytics/learn/privacy.html

2. Yandex.Metrica. You can find detailed information about using the system here: https://yandex.ru/legal/confidential/

3. Yagla. You can find detailed information on using the system here: https://yagla.ru/p_polozhenie-o-zashchite-personalnyh-dannyh/

4. Lptracker. You can find detailed information about using the system here: http://lptracker.io/index_land_pc1.php?&utm_source=land_pc5

5. Facebook Pixel. You can find detailed information about the use of the system here: https://www.facebook.com/privacy/explanation

6. VK Pixel application. You can find detailed information about using the system here: https://vk.com/page-19542789_53869861

7. RedConnect. You can find detailed information about using the system here: https://web.redhelper.ru/nx/eula?c=rhlp&site=https://redhelper.ru

8. Captcha from Google (reCAPTCHA).

9. Subscribe to the Telegram channel. You can find detailed information about using the system here: https://tlgrm.ru/privacy

10. Sendpulse https://sendpulse.com/legal/pp

 

 

Transfer of personal data to another country or state

The Company does not transfer the personal data it receives to the territories of other states. In the event of transfer, the Company is obliged to ensure that the foreign state to whose territory the personal data is supposed to be transferred ensures adequate protection of the rights of the subjects of personal data, before such transfer begins.

Cross-border transfer of personal data to the territory of foreign states that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:

· the presence of written consent (including using the hardware of the company X website on the Internet) of the subject of personal data for the cross-border transfer of his personal data;

· execution of an agreement to which the subject of personal data is a party.

When placing data in countries that have not been approved by the EU authorities, the Company will take legal measures as stipulated by the contract.

 

 

Accessing personal data, updating, deleting information and changing privacy settings

Upon your request to the authorized person or to the company address, we will provide you with information about whether we store or process for third parties any of your personal information. To request this information, please contact us at  info@apl-home.com

You have the right to access your personal information and privacy settings at any time, to change or delete them. You can also do this by sending us a request by email to info@apl-home.com or to an authorized person. We will promptly respond to your request within a reasonable time. Within 30 days, we will change, update or delete information about you with all personal data.

You may also request that personal data be transferred to you or another organization by sending a request to the authorized DPO employee at apl@apl-home.com , who will transfer the personal data to you and assess the technical feasibility of transferring the subject's data to another organization.

 

Storage and protection of personal data

The personal information you provide in connection with your use of the site is protected in several ways.

· Your personal information is stored on secure servers, which can only be accessed by a limited number of Company employees and affiliated organizations using a password.

· When personal data is transmitted via the website, the information is encrypted.

We do our best to protect the personal information sent to us, both during transmission and once we receive it. However, no method of transmitting information over the Internet, or of storing information electronically, is completely secure. And although we take into account the sensitive nature of the personal information we receive, process, and store, as well as the current state of technology, in order to select adequate measures to protect your personal information, we cannot guarantee its absolute security.

If you have any questions regarding security on our website, please contact us at info@apl-home.com or our designated DPO at apl@apl-home.com .

 

Ensuring the security of personal data

The security of personal data processed by the Company is ensured by the implementation of legal, organizational and technical measures necessary to ensure compliance with the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

· appointment of officials responsible for organizing the processing and protection of personal data;

· limiting the number of persons allowed to process personal data;

· familiarization of subjects with the requirements of EU legislation and the Operator’s regulatory documents on the processing and protection of personal data;

· organization of accounting, storage and circulation of media containing information with personal data;

· identification of threats to the security of personal data during their processing, formation of threat models based on them;

· development of a personal data protection system based on the threat model;

· checking the readiness and effectiveness of using information security tools;

· restriction of user access to information resources and software and hardware for information processing;

· registration and accounting of actions of users of personal data information systems;

· use of antivirus tools and means of restoring the personal data protection system;

· application, where necessary, of firewalling, intrusion detection, security analysis and cryptographic information protection tools;

· organization of access control to the Operator’s territory, security of premises with technical means for processing personal data.

 

 

Data retention periods

We will retain your information for as long as your account is active, as long as the information is needed to provide you with services, or as necessary to comply with our legal obligations. If you wish to delete your account or request that we no longer use your information to provide you with services, you may contact the designated person at info@apl-home.com or the company address. We will respond to your request within 30 days. We will retain and use your information for as long as it is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Opting out of marketing activities, receiving updates, newsletters and/or informational messages

You may opt out of receiving email updates and newsletters from the Company and/or emails from partners by making the appropriate selection or by contacting the Data Protection Officer (DPO) by email at info@apl-home.com . You may also opt out of receiving such messages during the registration process. In this case, you will receive notifications from the Company in the event of changes to the Terms of Service or the Terms of Information for Users of the Site. In addition, we will always send you messages related to the provision of services, including the registration letter. Generally, you cannot opt ​​out of receiving such messages, which are not advertising. If you do not want to receive them, you can delete your personal data and cancel the receipt, contact the DPO with a request to delete the data at info@apl-home.com , or not use the site. If you do not agree to comply with all or individual provisions of this agreement, do not use the site and leave it immediately.

 

Changes to the privacy policy

The Company reserves the right to make changes to the Privacy Policy at any time at its sole discretion and undertakes to specifically notify you of significant changes by email or other means. Any changes to the Privacy Policy can always be found on the pages of the website or by contacting the responsible DPO person – by email apl@apl-home.com , requesting information about the changes. We do everything to ensure that information about changes to the Privacy Policy is available to you at any time. If, as a result of such changes, you want to change the procedure for the permitted use of your personal information by the Company, you can do so by following the procedure described in the Updating personal information and privacy settings section or by contacting us at info@apl-home.com or the responsible DPO employee.

Once changes and updates to the Privacy Policy are posted on the site, you will be deemed to have become aware of any material changes to the Privacy Policy and they will apply to you, with the following exception: if at the time you provide personal information to the Company you are given the opportunity (as we currently do) to limit the use of such information for communications with you by the Company or third parties, the Company will not have the right to change your preferences in this regard without your express consent. However, if the Company ceases to exist as a legal entity, transfers assets, control and management of them to another company, merges, takes over or is acquired by another company, the Company may, without your consent, provide to such company information about users and customers related to the part of the commercial or non-commercial activities that has been transferred to the other company. In this case, the Company is obliged to place a notice of such sale of assets, acquisition or merger on this site.

 

Cookies and Tracking Technologies

When you browse the Internet, the Site may automatically collect information such as your Internet service provider, browser type and version, operating system and device type, average time spent on our site(s), pages viewed, information accessed, the Internet Protocol (IP) address used to connect your computer to the Internet, and other relevant statistics. This information is sometimes referred to as web analytics or clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve the quality of the services we offer you, improve our marketing strategy and analytics, and ensure good functionality of the site.

The Company and our affiliates, analytics and service providers use technologies such as cookies, beacons, tags and scripts to provide the functionality of the site. These technologies are used to analyze trends, administer the site, track users' movements around the site and gather demographic information about our users as a whole. We may receive reports based on these companies' use of these technologies on an individual basis and in the aggregate.

· A cookie is a small unique text file that a website sends to your computer when you visit that site. We may use session cookies, which are deleted automatically when the user closes their browser, and/or persistent cookies, which remain on the user's computer until manually deleted. Most web browsers can either warn you when cookies are being used or refuse to accept cookies altogether. If you do not want us to use cookies in your browser, you can set your browser to refuse cookies or to notify you when a website tries to set cookies on your computer. Refusing cookies may affect your ability to use this site.

· We partner with a third party to either display advertising on our website or to manage the display of our advertising on other sites. The third party we partner with may use technologies such as cookies to collect information about your activities on this site and other sites in order to show you advertising based on your browsing activities and interests. If you are located in the European Union and do not want this information used to provide you with interest-based advertising, you can opt-out by clicking  here . You can also control the display of advertising by deleting cookies from your browser. Please understand that this does not mean that you have opted out of receiving advertising. You will still receive regular advertising.

 

Web beacon

A web beacon is a small graphic file on a web page that can be used to obtain certain information from your computer, such as your IP address, how long you have been viewing the web page, your browser type, and whether you have cookies previously created by the same server.

The Company uses the specified web beacons in strict accordance with applicable law. The Company or its subsidiary operators – service providers may use web beacons to monitor the performance of third-party websites that provide us with various services, including marketing services, or to collect aggregated statistics on online visitors to the site and manage cookies.

You have the ability to disable some web beacons by blocking the cookies associated with them. In this case, the web beacon will be able to register an anonymous visit from your IP address, but the information will not be recorded in the cookie.

If you subscribe to our newsletters or other materials, we may monitor the actions of recipients, for example, through embedded links within messages, we may collect information about the number of recipients who have opened a particular message. This information is collected in order to assess which sections of the site are of greatest interest to users.

 

Links to third party sites

Our site contains links to other websites whose privacy policies may differ from the Company's privacy policy. If you provide personal information on any of these sites, your information will be processed in accordance with the privacy policy of that site. We encourage you to carefully read the privacy policy of each site you visit.

 

Widgets for social networks

Our website may include social media features and widgets, such as the Share This button and interactive mini-programs that run when you interact with the site. These features may collect your IP address, track which page you are visiting on our site, and set a cookie to enable them to function properly. Social media features and widgets may be hosted either directly on our site or by a third party. Your interactions with these features are governed by the privacy policy of the company providing them.

 

Email addresses for referral program

If you want to use our referral program to tell a friend about our site or a specific page on our site, you will need to provide their name and email address to the DPO. We will send them a one-time email inviting them to visit our site. The company stores this information for the sole purpose of sending the email and tracking the effectiveness of our referral program.

Your friend may contact the DPO at info@apl-home.com to request that this information be removed from our database.

 

Receiving and processing personal data from children – subjects under 21 years of age

We do not intend to solicit or collect personal information from anyone under 18 years of age. If you are under 18, please do not enter information on this site or use our services. If you believe that your child under 18 has entered personal data, please notify the responsible person DPO at info@apl-home.com so that we can delete the data and the child's account.

If suspicions arise related to the minority of a website user or a company client, a company employee interacting with the subject or an authorized DPO employee has the right to request the consent of a parent or guardian to process the child's personal data.

 

Complaints related to privacy

Individuals residing in certain countries, including countries in the European Economic Area, have certain legal rights in relation to their personal data. You may have the right to request access to the information, as well as to request that the information be updated, deleted or corrected, subject to any exceptions provided by law.

To the extent that the Company that processes your personal data is subject to the EU General Data Protection Regulation, the Company relies on its legitimate interests, described above, to process your data. When the Company processes certain personal data for the implementation of its own direct marketing activities, you have the right to object at any time to the use of your personal information by the Company for these purposes.

The Company takes user privacy seriously. If you believe that the Company has not complied with this Privacy Policy with respect to your personal information, you may contact the Data Protection Officer DPO at info@apl-home.com . In your letter, please describe in as much detail as possible the incidents of the alleged violation of the Privacy Policy by the Company. We will investigate your complaint as soon as possible. If you do not receive confirmation of receipt of your complaint within 30 days of sending the letter or your complaint is not resolved satisfactorily, you can always contact a third-party partner in the field of dispute resolution in the field of information and personal data protection, or file a complaint with your local authorities responsible for resolving data protection disputes.

Information on updates to data protection laws and regulations, as well as data protection authorities: https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en

If you have any questions about this Privacy Policy, our practices, or your interactions with the website, you can contact our Data Protection Officer at  apl@apl-home.com .

Company details

"APL Alexander Real Estate Ltd"
HE316361

ADDRESS:

59 Amathoundos Ave., No. 3

4532 Limassol, Cyprus

Coordinates: 34.708241, 33.125329

PHONES:

Office: (+357) 25 43 10 18

Fax: (+357) 25 43 15 14

E-MAIL: info@apl-home.com , apl@apl-home.com

Link to Regulation (EC) 016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation): http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.119.01.0001.01.ENG&toc=OJ%3AL%3A2016%3A119%3ATOC

Information on updates to data protection laws and regulations, as well as data protection authorities: https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en