Last Modified: May 28th, 2020
“THÈA” website (https://www.thearealty.com) services (the “Website”, “Site”, the “Service”) is operated by “QLS TRAVEL LTD” (in this document “QLS”, “THÈA”, “us”, “we”, or “our”).
The term “you” refers to the user or viewer of our Website.
1. Who are we?
2. How do we collect information?
3. What information do we collect?
4. How we use Information we collect?
5. Controlling your information
6. International Transfer of Information
7. Cookies and Similar Technologies
1. Who are we?
We are QLS, a company in Cyprus providing travel services and real estate consulting services to clients from all over the world. Our registered address is: 7A Atho St. – 1087 Nicosia – Cyprus.
THÈA represents a trademark that refers to a bundle of services offered by the company QLS related to real estate consulting services as well as construction management services, for properties and works located in Greece.
2. How do we collect information?
You are free to explore the Website without providing any Personal Information about yourself.
When you visit the Website, we request that you provide Personal Information about yourself, and we collect Navigational Information within the following ways:
– We obtain information about you when you contact us to enquire about our services.
– We also collect information from you if you leave a comment on our blog.
– We collect information to allow us to fulfil our obligations to our clients, and to respond to business enquiries.
3. What information do we collect?
3.1 “Sensitive Information”
We do not gather sensitive personal data (e.g. health, genetic, biometric data; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, and criminal convictions). We expressly request that you do not provide any such sensitive data to us.
3.2 “Information About Children”
The Website are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at email@example.com, so that we may delete the information.
3.3 “Personal Information”
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Website, and information about you that is available on the internet, such as from Facebook, Instagram, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.
Personal Information also includes Navigational Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below. Except for this, we do not collect Sensitive Information from you.
3.4 Third Parties
Information we collect from third parties:
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.
We Never Sell or rent Personal Information
We will never sell or rent your Personal Information to any third party.
We will never share your information.
We will never share your information with third parties for marketing purposes.
4. How we use Information we collect
Use of Personal Information
– improve your browsing experience by personalizing the Website;
– send information or THÈA’s content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
– promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
– provide other companies with statistical information about our users – but this information will not be used to identify any individual user;
– meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
4.2 Service Providers
We may pass your information to third party service providers who we have engaged for the purpose of completing tasks and providing services to you on our behalf (for example, we may provide your contact details to the Search Engine Optimisation company we work alongside). We disclose only the personal information that is necessary to deliver the service.
We also use a number of 3rd party services to help us fulfil our contractual obligations – for example, a modern workspace called Dropbox. We have verified that these 3rd party services are GDPR compliant (or are working towards GDPR compliance).
4.3 THÈA’s Partners
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
4.4 Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by THÈA on the Website. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
4.5 Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor/customer located in the European Economic Area (“EEA”), QLS is the data controller of your personal information. QLS’s Data Protection Officer can be contacted at firstname.lastname@example.org. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
4.6 Use of Navigational Information
We use Navigational Information to operate and improve the Website. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about THÈA.
4.7 Customer Testimonials and Comments
We may post customer testimonials and comments on our Website, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
5. Controlling your information
You have certain rights concerning the information we hold about you, as defined under the General Data Protection Regulation (GDPR). If you wish to exercise these rights, please contact us, including your email address in the first instance (this is the unique identifier we use to identify and collate personal information).
5.1 Requesting a copy of your information
You may request a copy of any data we hold about you. Upon request, we will provide a CSV file (which you may open in a program such as Microsoft Excel) or alike, containing the personal data we hold on record about you.
5.2 Updating or correcting your information
The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please contact us so we may correct our records.
5.3 Deleting your information
You have the right to request erasure of your personal information. Unless there is a compelling reason for the data not to be erased (for example, if we need to use that data to fulfil our contractual or legal obligations), your personal data will be deleted on request.
Users may have the ability to leave comments on our blog. To maintain flow of conversation, blog comments will not normally be deleted (unless there is a compelling reason to do so), but all personally identifying information will be removed.
5.4 Automated decision making
We do not use any personal information for automated decision making or profiling; your data is not subject to automated decision making or profiling.
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
– You can request access, correction, updates or deletion of your personal information.
– You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
– If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
– You have the right to complain to a data protection authority about our collection and use of your personal information.
To exercise any of these rights, please contact us at email@example.com.
We will respond to your request to change, correct, or delete your information within a reasonable time frame and notify you of the action we have taken.
5.5 Anti-Spam Policy
We are not allowed to send unsolicited commercial email in violation of applicable laws and requires the inclusion in every email sent of an “opt-out” mechanism and other required information.
5.6 Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at firstname.lastname@example.org. Customers cannot opt out of receiving transactional emails related to their account with us.
6. International Transfer of Information
International Transfers within QLS’s Entities
To facilitate our global operations, we transfer information to all continents and allow access to that information from countries in which the QLS’s affiliated entities have operations for the purposes described in this policy.
International transfers to third parties
7. Cookies and Similar Technologies
Google Analytics: Google Analytics sets cookies to help us accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that our website is responding to your needs in the best way possible.
Comments/messages: When you send us a comment or a message through our contact form, cookies are set to store your name and email address. This is so that if you wish to leave another comment in the future, we can statistically verify that you are not a new visitor.
By using and browsing the THÈA’s website, you consent to cookies being used in accordance with this Policy.
If you do not consent, you must turn off cookies or refrain from using the site. Most browsers allow you to turn off cookies. To do this, look at the ‘help’ menu on your browser. Switching off cookies should not noticeably restrict your use of this website.
Flash Cookies and Other Third-Party Tracking Technologies
Third Party Tracking Technologies
What are cookies?
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
Cookies provide a convenience feature to save you time or tell the Web server that you have returned to a specific page. For example, if you personalize pages on our Website, or register for a Subscription Service, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.
Cookies set by the website owner (in this case, QLS) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.
We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Website and Subscription Service. For example, THÈA keeps track of the Website’s pages you visit, in order to determine what portion of the Website or Subscription Service is the most popular or most used. This data may be used to deliver customized content and promotions within the THÈA Website and Subscription Service. Third parties serve cookies through our Website for advertising, analytics and/or other purposes. This is described in more detail below.
What types of cookies do we use and how do we use them?
We use specific types of first- and third-party cookies served through our Website. The list of the cookies used by THÈA includes:
– Essential website cookies: These cookies are strictly necessary to provide you with services available through our Website, Subscription Service to use some of its features, such as access to secure areas (if available).
– Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Website and Subscription Service are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
– Analytics and customisation cookies: These cookies collect information that is used either in aggregate form to help us understand how our Website and Subscription Service are being used or how effective our marketing campaigns are, or to help us customise our Website for you.
– Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
– Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Website and Subscription Service through third party social networking and other websites. These cookies may also be used for advertising purposes too.
How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided below.
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. You may opt out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.
Essential website cookies: because these cookies are strictly necessary to deliver the Website to you, you cannot refuse them. You can block or delete them by changing your browser settings however, as described above.
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognise or track visitors to a website. We employ a software technology called clear GIF (a.k.a. Web Beacons/Web Bugs), that help us better manage the Website and Subscription Service by informing us what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear GIFs are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. We use clear GIFs or pixels in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear GIFs in emails to our customers’ Personal Information.
Do you use Flash cookies or Local Shared Objects?
The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as “Flash cookies.” THÈA does not use Flash cookies.
Do you serve targeted advertising?
Third parties may serve cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.
Where can I get further information?
THÈA takes security seriously. In order to protect your information from loss, misuse or unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include the following:
– Data minimisation
– Password best practice
– Security best practice concerning devices (PCs, laptops, mobile devices), online accounts, website hosting, physical access and storage
– Staff training and accountability on data protection
A copy of our internal Data Security Policy is available on request.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
8.1 Social Media Features
8.2 External Websites
We may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Website if you so request, as described in “Opting Out and Unsubscribing” below.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
8.3 Data Breaches
Our Data Security Policy includes a clear process for handling a personal data breach, should one occur. Where appropriate, THÈA will promptly notify you of any unauthorized access to your personal information.
If you wish to raise a complaint on how we have handled your personal information, you can contact us directly and we will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the Personal Data Protection Authority.
– The content of the pages of this Website is for your general information and use only. It is subject to change without notice.
– Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
– Your use of any information or materials on this Website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
– This Website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
– All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the Website.
– Unauthorized use of this Website may give rise to a claim for damages and/or be a criminal offense.
– From time to time, this Website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
– Your use of this Website and any dispute arising out of such use of the Website is subject to the laws of Cyprus.
This Website and its content is copyright of THÈA. All rights reserved.
Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:
– you may print or download to a local hard disk extracts for your personal and non-commercial use only
– you may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material
You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.
QLS TRAVEL LTD
7A Atho St.
1087 Nicosia – Cyprus