Privacy Policy

This privacy policy (“Policy”) describes how Robura Ltd (“Robura”, “we”, “our”, or “us”) collects, uses, shares, and stores personal data. This Policy applies to the site, sub-sites, and services (collectively, “Services”).

1.Type of personal data held by Robura:

 ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal data held by Robura concerns the following categories:

  1. Clients
  2. Robura’s employees or applicants for employment
  3. Individuals employed by Robura

The data to be collected includes:

  1. Basic Identity Identifiers (such as name, address, telephone number and e-mail address)
  2. In the case of Robura's employees or applicants for employment, personal data, as CV for job application form
  3. The necessary data we need to provide our services to the clients, including the information contained in the records that we manage, and which concern the said client
  4. In relation to asset management services, we may need, property details - registration of the property and title deeds, LRO searches, photographs of the property, address of the property etc.
  1. For what purposes do we process your personal data?

We collect and process your personal data for the purpose of providing our asset management services to you and for the purpose of complying with our obligations under any contract we may have with you and with the Law. We may also use your personal information to send newsletters and other updates concerning us, provided that you are subscribed to the list of recipients of such emails or that you have not objected to that use.

The legitimate basis for the processing of your personal data is (a) the ability to perform our services, (b) our compliance with our legal obligations, and (c) the foundation, exercise, or support of legal claims. To send newsletters and / or event invitations, the legitimate basis of the processing is your consent.

  1. To whom we share your personal information with?

We are committed not to share personal data to third parties.

Exceptionally, we may share your personal data:

(a) to the competent public services and judicial authorities, whether to comply with our legal obligations or to exercise and defend our rights, and

(b) to third parties providing services to us, such as IT Service Providers, service providers and storage facilities, translation agencies, bank institutions, clients and lawyers with whom we work, and only to the extent which is necessary for the provision of services to us and / or you. When the said service providers perform services to us, they act as processors and therefore process personal data solely on behalf of and on the basis of recorded orders by us and are not entitled to re-use the data for their own benefit. Information may also be shared to potential buyers/sellers for the purposes of providing asset management services.

  1. Accessing this website and creation of log files

Information are collected every time this website is accessed or used. These data and information are stored in log files on the server and can include:

The temporary storage of data and log files is lawful pursuant to Art. 6 (1) General Data Protection Regulation. The IP address is temporarily stored in the system as it is necessary to provide website access to the User’s computer. The IP address is retained while that website is being accessed. These log files are stored to ensure website functionality, optimize the content of our website, and ensure the security of our IT system.

The data will be deleted when they are no longer needed for the purpose they were collected. For data collected to provide access to the website, this will be at the end of every session.

For log files, this will occur after seven days at the latest. Some data may be preserved for a longer period of time, in which case user IP addresses are deleted or removed, rendering it impossible to link the data to any individual.

  1. Cookies

Our website uses cookies. Cookies are small data files, created and stored by the Internet browser on your computer’s hard drive. Accessing a website may result in a cookie being saved on your operating system. This cookie contains a specific string of characters that allows the browser to be clearly recognized every time the website is accessed.

We use cookies to make our website more user-friendly.

The processing of personal data based on the use of cookies is lawful pursuant to Art. 6 (1) GDPR.

The purpose of these technical cookies is to simplify website use.

Cookies are stored on the User’s computer and transferred to us. That is why you, as the User, have full control over cookie implementation. You can deactivate or restrict cookies by changing your browser settings. Cookies already stored on your hard drive can be deleted at any time. This can also be done automatically. However, disabling cookies for our website may result in some functions not working correctly.

  1. Contact form and email contact

There are contact forms on our webpages that can be used to communicate electronically. When registering, the data entered by you into the online data entry form will be transmitted. Your consent is required for the processing of this data, and you will be referred to our Policy and asked to grant your consent when you send the form.

Alternatively, contact may be initiated using an email address provided by you. In this case, the personal data provided in the email will be stored. This information will not be passed on to third parties.

The processing of information received from the sending of an email is lawful under Art. 6 (1) (b) GDPR.

These data are only stored for the purposes of processing that communication. The data will be deleted when they are no longer needed for the purpose they were collected.

Your Reinforced rights:

Robura has taken appropriate measures to provide any information relating to your rights as well as the exercise of these rights. Under Chapter III of the GDPR you have the following rights:


  1. Transparent information, communication and modalities for the exercise of your rights

You have the right to be provided with your data freely and in an intelligible and easily accessible form. Following your request, we shall provide information without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. In that case we will inform you for the reasons of the delay.


  1. Information to be provided where personal data are collected from the data subject

You have the right to know the contact details of the agent who collects your data, the purposes of the processing for which the personal data are intended, the legal basis for the processing, the recipients or categories of recipients of the personal data and where applicable the fact that the controller intends to transfer personal data to a third country.


  1. Right of access

You have the right to request and receive a copy of your personal data undergoing processing. However, for any further copies requested, we may charge you a reasonable fee that is based on administrative costs.


  1. Right to rectification

You have the right to obtain from us within reasonable time the rectification of inaccurate personal data concerning you.


  1. Right to erasure (‘right to be forgotten’)

There is a right to ask for the erasure of your personal data and no longer processed where the personal data are no longer necessary in relation to the purposes for which they are controlled or otherwise processed.

Hence, in the cases where we retain and process personal data in accordance with the provisions of Article 6(1)(c) of the GDPR, we may object to such a request and may keep the relevant personal data that are required in order for us to comply with our legal obligations or the legal obligations of a Controller that cooperates with us pursuant to the terms of a Data Processing Agreement.


  1. Right to restriction of processing

We ensure that Robura has in place a procedure where you have the right to restrict the processing of your personal data. Nonetheless, for those personal data that are necessary for compliance with a legal obligation, we may object to the restriction.


  1. Right to data portability

You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.


  1. Right to object

You have the right to object to the processing of your personal data. However, since we lawfully processes such data under Article 6(1)(c), we will still have the right to process the data.


  1. Automated individual decision-making, including profiling

You have the right no to be subject to a decision solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects.


  1. Right to make a complaint

Any complaint in relation to the use of personal data by Robura may be submitted to us either in writing or by email with a full description of the circumstances on which the complaint is based. Robura assures you that all related complaints/complaints will be thoroughly investigated.Those affected may also contact the Office of the Commissioner for Personal Data Protection at


Contact Information

Robura Ltd


Address: 2 Nikokreontos, Nicosia 1066, Cyprus