Contact Details

 
Phone Toll Free (local calling)
77 77 04 04
Divider
Phone Administration
+357 22 21 00 04
Divider
Email Email
info@unihalls.eu
Divider
Location Address
14 Porfyriou Dikaiou,
2414, Engomi,
Nicosia, Cyprus
   

 

PRIVACY POLICY NOTICE (GDPR)

CONTENTS
CLAUSE
1. Important information and who we are 1
2. The data we collect about you 2
3. How is your personal data collected? 4
4. How we use your personal data 4
5. Disclosures of your personal data 7
6. International transfers 8
7. Data security 8
8. Data retention 8
9. Your legal rights 8
10. Glossary 9
 
 
Introduction
Welcome to ROTOS DEVELOPERS LTD privacy notice. 
ROTOS DEVELOPERS LTD respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website to choose an accommodation/room type in the uniHALLS premier (the «uniHALLS premier») and in the uniHALLS trinity (the «uniHALLS trinity») (the «uniHALLS premier» and the «uniHALLS trinity» together referred to as the «uniHALLS properties»)(regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 
ROTOS DEVELOPERS LTD is responsible to manage the uniHALLS properties including the renting of Suites/rooms in the uniHALLS premier and in the uniHALLS trinity to students studying in a University/College in Cyprus.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here [LINK]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
 

1. Important information and who we are

Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you accept to receive our newsletter/offers/promotions/events/packages or purchase a product or service or take part in a competition or [any other example]. 
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them. 

Controller
ROTOS DEVELOPERS LTD is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exerciseyour legal rights, please contact the DPO using the details set out below. 

Contact details of DPO
If you have any questions about this privacy notice or our privacy practises, please contact our DPO in the following ways:
Full name of legal entity: ROTOS DEVELOPERS LTD
Name of DPO: Avraam Michaelides
Email address:avraam@rotosgroup.com
Postal address: 16 PorfyriouDikaiou, 2414, Egkomi, Nicosia, Cyprus
Telephone number: +35722665818

Changes to the privacy notice and your duty to inform us of changes
We keep our privacy policy under regular review. Thisversion was last updated on the 4th of June 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
 

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories of more sensitive personal data which require a higher level of protection, such as information about a person’s health, illness, disability etc.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes title,first name, maiden name, last name, username or similar identifier, Identity CardNo./Passport No.and relevant scanned copy/Nationality/gender.
Contact Data includes current/billing address (street, town/city, country, P.C., scanned copy of utility bill), delivery address, email address and telephone numbers (Home No./Mobile No.).
Next of kin and emergency contacts information includes their names and phone numbers.
Guarantor’s Data includes his/hertitle, first and last name/Identity Card No.or Passport No. and relevant scanned copy/Nationality/email address/Mobile Phone/Address/Town or City/Country/ P.C./Guarantor’s utility bill.
General Data includes information such as how she/he heart about uniHALLS.
Financial Data includespayment card details (full name on card, card number, expiration date, CCV2/CVC2).
Course Data includes the University/College, Course of Study, Duration of Study, Year of Study, Student Number and University Letter of Enrolment/acceptance.
Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website]. 
Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].  
Usage Data includes [information about how you use our website, products and services]. 
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data willnot directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also collect, store and use the following "special categories" of more sensitive personal information which require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which are required by law to maintain when processing such data. We may process special categories of personal data in the following circumstances:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations.
3. Where it is needed for the public interest.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.  

Our obligations
We will use information about your disability status, to ensure your health and safety in the uniHALLS properties, 
We will use information about your disability status to provide you with the appropriate Suite/room type. 

Do we need your consent? 
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data.  If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.  You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us. 

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of the Lease Agreement and/or any other related agreement/contract, we already have with you or which will be signed between our company and you and you fail to provide that data when requested, we may not be able to perform the Lease Agreement and/or any other related agreement/contractwe have or execute and perform the Lease Agreement or any of the Agreement/Contract which we are trying to enter into with you (for example to provide you with goods and services). In this case, we may have to cancel the Lease Agreement/reservation of the Suite/room and/or any other relevant agreement but we will notify you if this is the case at the time. 
 

3. How is your personal data collected?

We collect personal information about you[Identity, Contact and Financial Data], your guarantor and next of kin/emergency contactsby filling in forms and/or documents/applications and/or through the application process in our website when choosing an accommodation/room type at the uniHALLS properties or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies] Please see our cookie policy [LINK] for further details.

We may also collect information from the University/College in which you are registered to study and from the University Letter of Enrolment/acceptance.
 

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform anylease agreement/contract which we have entered into or execute and perform any lease agreement/contract we are about to enter into or execute.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
We may also use your personal information in the following situations, which are likely to be rare:
Where we need to protect your interests or someone else’s interests.
Where it is needed in the public interest or for official purposes.
Click here [LINK TO GLOSSARY, LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
 
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 
 
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a Lease Agreement/ contract with you
To try to allocate you in a room. Gender Necessary for our legitimate interests
To process and deliver your accommodation including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e)Marketing and Communications
(a) Performance of a Lease Agreement/ contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a Lease Agreement/ contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e)Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  (a) Identity
(b) Contact
(c) Technical
(d) General
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
(a) Manage payments, fees and charges
(b) To collect and recover money owed to us
Guarantor’s Data:
  1. Identity
  2. Contact
(a) Performance of a Lease Agreement/  contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To contact next of kin/emergency contacts in cases of emergency Next of kin/emergency contacts Data:
a) Identity
b) Contact
Necessary for your vital interests
To try to allocate you in a room that will accommodate your needs. Disability Data:
Type of disability (if any)
(a) Performance of a Lease Agreement/  contract with you
(b) Necessary for our legitimate interests
(c) Explicit Consent
 
Marketing 
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us 
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 
You will receive marketing communications from us if you have requested information from us or if you have purchased [goods or service] from us andyou have not opted out of receiving that marketingor if you provided us with your details when you applied/registered in our website.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us. 
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a Suite/room reservation or a product/service purchase.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see
[LINK TO YOUR COOKIE POLICY]
Change of purpose 
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
Internal Third Parties as set out in the Glossarybelow. 
External Third Parties as set out in theGlossarybelow.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
 

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, representatives, contractors, guarantors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In any case, we will retain your personal data for the maximum period of 3 (three) years after the expiration/termination of the Lease Agreement.
 

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within 20(twenty) working days. Occasionally it may take us longer  if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 
 

9. Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES
Internal Third Parties
Other companies in the Company’s Group, acting as joint controllers or processors, and who are based in […] and provide […]services and undertake […].
External Third Parties
Service providersacting as processors based in[…] who provide […]services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in […]who provide consultancy, banking, legal, insurance and accounting services.
[Details of any other third parties, such as market researchers, fraud prevention agencies, price comparison sites etc.]

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
Withdraw consent at any time where we are relying on consent to process your personal data.However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


 
Headquarters:
16 Porfyriou Dikaiou,
2414, Egkomi, Nicosia
 
Tel: 77 77 04 04
Admin: +357 22 21 00 04