Privacy
Policy

We collect personal data from the following sources:

• Direct Data: name, email, phone, postal address, nationality, viewing preferences, feedback, correspondence records
• Technical Data: IP addresses, device/browser data, site usage, cookies and tracking data
• Collection Sources: website inquiries, property viewings, office walk-ins, event registrations, referrals, and third-party lead providers.
• Purpose & Legal Basis
  We process personal data for:
  
  • Lead management and customer relationship management (CRM)
  • Delivering property services and arranging property viewings
  • Responding to inquiries and service requests
  • Sending updates, newsletters, or marketing communications
  • Internal analytics and service improvements
  Legal bases include
  
  • Consent (e.g., opt-in for marketing communications or analytics tracking)
  • Contract necessity (e.g., delivering requested services or agreements)
  • Legitimate interests (e.g., improving services, security, or relevant communications where a client has shown prior interest)
• Cookies & Tracking
  We use cookies for technical functionality, performance, and analytics. Non-essential cookies are deployed only with explicit consent. Users can manage or withdraw cookie preferences at any time.
• Marketing Communications
  We collect contact details provided via website inquiries, property viewings, walk-ins, and other lead sources. These may be added to our marketing database to provide updates about properties and related services.
  
  • We rely on explicit consent where given (e.g., form submissions) or on legitimate interests where an individual has engaged with our services, provided such communication is relevant and non-intrusive.
  • Individuals may opt out of marketing at any time, and we will honor such requests within 7 days.
  • Sensitive personal data will never be used for marketing purposes.
• Data Sharing & Third-Party Processing
  We do not sell personal data to third parties. However, to operate effectively, we may share data with trusted third-party service providers, including:
  • Mailing platforms (for newsletters and campaigns)
  • CRM providers (for client and lead management)
  • Payment processors (for handling secure transactions)
  • Cloud hosting and analytics providers (for secure storage and site performance)
  All third-party providers act only on our instructions and are bound by strict confidentiality and data protection agreements.
• Refunds & Transactions
  Where payments or reservations are processed via our platforms, such transactions are subject to our Refund and Cancellation Policy (available separately on our website). Payment details are handled securely by authorized payment processors in compliance with applicable financial and data protection regulations.
• Data Security & Retention
  We secure personal data using access controls, encryption, secure servers, and staff training. Data is retained only for as long as necessary for the purposes collected, after which it is securely deleted or anonymized in accordance with legal requirements.
• Data Subject Rights
  Under the DPA, individuals have the right to:
  
  • Access, rectify, or delete their personal data
  • Withdraw consent or object to processing
  • Request restriction or portability of their data
  Requests will be addressed in accordance with the DPA and applicable regulations.
• Breach Notification
  In case of a data breach that poses a risk to individuals’ rights and freedoms, we will notify the ODPC and affected individuals within 72 hours.
• DPO & Registration
  If applicable, SMB Properties will register with the ODPC and appoint a Data Protection Officer (DPO) to oversee compliance.
• Policy Updates
  This Privacy Policy may be updated periodically to reflect legal changes or operational needs. The latest version will always be available on SMB Properties’ website. Continued use of our services indicates acceptance of the current policy.