Legal
Privacy Policy
1. Introduction and Scope
Welcome to [abuda.com] ("we," "us," or "our"). We are a leading real estate technology platform utilizing advanced data analytics and Artificial Intelligence to provide property valuations, market insights, and portfolio management services.
This Privacy Policy explains how we collect, process, use, and protect your personal information when you interact with our website, mobile applications, and professional services in Cyprus, Germany, the wider EU/EEA, and Israel. We are committed to a "Privacy by Design" approach, ensuring that your data is handled with the highest level of integrity and in accordance with applicable regulations such as the General Data Protection Regulation (GDPR), applicable Cypriot and German data protection law, and Israel's Privacy Protection Law (Amendment 13).
2. The Data Controller and Contact Information
The entity responsible for your personal data is abuda.com, located at Friedrichstr 68, 10117 Berlin, Germany.
To ensure the highest standards of protection, we have appointed a Data Protection Officer (DPO) who oversees our global privacy strategy. For any inquiries or to exercise your rights, please contact our privacy team at:
Email: hello@abuda.com
Mailing Address: Friedrichstr 68, 10117 Berlin, Germany.
3. Categories of Personal Data We Collect
We collect information that identifies or relates to an identifiable natural person ("Personal Data"). This includes:
- Identifiers: Name, email address, telephone number, and postal address.
- Professional and Financial Information: Job title, company name, and payment information for our subscription services.
- Property and Geolocation Data: Precise property addresses, ownership details (sourced from public registries such as the Cyprus Department of Lands and Surveys and the German Grundbuch land registry), and GPS coordinates if you enable location services.
- Digital Identifiers: IP addresses, browser types, device IDs, and online activity collected through cookies and tracking pixels.
- AI Interaction Data: Logs of your interactions with our automated valuation models (AVMs), chatbots, and predictive analytics tools.
4. Purposes and Legal Basis for Processing
We process your data based on the following legal frameworks:
- Performance of a Contract: To provide our PropTech services, manage your account, and process transactions.
- Informed Consent: For marketing communications, the use of certain cookies, and processing of "especially sensitive" data.
- Legitimate Interests: To improve our AI models, enhance website security, and conduct market research.
- Legal Obligation: To comply with tax laws, anti-money laundering regulations, and real estate transparency requirements applicable in Cyprus and Germany.
Cookies and Similar Technologies
Beyond strictly necessary cookies required to operate our website, we use two optional categories of cookies, activated only with your consent via our cookie banner: Analytics cookies (to understand how visitors use our site) and Marketing cookies (for remarketing and ad measurement, including personalised advertising). You can accept, reject, or customise your choice for each category at any time using the "Cookie settings" button available on every page. The specific tools within each category are set out below.
Google Analytics & Google Signals (Analytics Measurement)
We use Google Analytics to understand how visitors use our website. Where enabled, Google Signals lets us associate Analytics data with information from Google accounts of users who have opted in to ad personalisation, supporting cross-device reporting and remarketing audiences. Google Analytics is enabled only after a visitor consents to Analytics cookies, and it is never loaded before that consent is given. Visitors can change or withdraw this choice at any time using the "Cookie settings" button available on every page.
Google Consent Mode
We use Google's Consent Mode to communicate a visitor's cookie choices to Google's tags (Google Analytics and Google Ads). Before a visitor makes a choice, and whenever a category is declined, Google 's tags operate in a denied state by default and do not store identifying cookies. Once a visitor grants or withdraws consent for Analytics or Marketing cookies, that choice is communicated to Google in real time, adjusting how — and whether — Google Analytics and Google Ads operate for that visitor, including measurement of Google Ads campaigns and personalised advertising.
Meta Pixel (Marketing & Conversion Measurement)
We use the Meta Pixel to measure conversions and support our marketing. It is enabled only after a visitor consents to marketing cookies, and it is never loaded before that consent is given. Visitors can change or withdraw this choice at any time using the "Cookie settings" button available on every page.
UTM Attribution
We capture UTM parameters associated with our contact form to understand the source of an enquiry. This is processed under the "legitimate interests" legal basis, tied directly to the enquiry you submit yourself — it is not placed behind cookie consent.
5. Artificial Intelligence and Automated Decision-Making
Transparency
We will notify you whenever you interact with an automated system or chatbot.
Explainability
Our property valuations are based on transparent data points. You have the right to request information about the logic behind our automated assessments.
Human Intervention
You may request a human review of any automated decision that significantly affects your legal or financial rights.
Ethical Training
We do not use unauthorized data scraping for AI training. Our models are trained on verified, lawfully obtained datasets.
6. Data Sharing and Third-Party Disclosure
We do not sell your personal data. We only share information with:
- Service Providers: Cloud hosting (e.g., AWS/AzureStack), payment processors, and analytics partners who are contractually bound to protect your data.
- Legal Compliance: Law enforcement or regulatory bodies when required by a valid court order or statutory obligation.
7. International Data Transfers
Operating across Cyprus, Germany, the wider EU/EEA, and Israel requires your data to be transferred across borders. We ensure that such transfers are protected by:
- Adequacy Decisions: Transfers between the EU and Israel are protected by mutual adequacy recognitions.
- Standard Contractual Clauses (SCCs): We implement EU-approved SCCs for transfers to jurisdictions without an adequacy decision.
8. Data Security and Retention
We implement industry-standard security protocols, including AES-256 encryption for data at rest and TLS 1.2+ for data in transit, and conduct regular security reviews and risk assessments.
We retain your data only for as long as necessary to fulfill the purposes outlined in this policy or to comply with statutory retention periods (e.g., 7 years for financial records or 25 years for specific health-related data in some jurisdictions).
9. Your Privacy Rights
Depending on your location, you may exercise the following rights:
- Right of Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete information.
- Right to Erasure ("Right to be Forgotten"): Request the deletion of your data when it is no longer required.
- Right to Restriction & Objection: Object to processing for direct marketing or restrict processing in specific scenarios.
- Right to Data Portability: Receive your data in a structured, machine-readable format.
- Right to Withdraw Consent: Revoke your consent at any time without affecting the lawfulness of previous processing.
We will respond to all valid requests within 30 days at no cost to you.
10. Children’s Privacy
Our services are intended for adults. In accordance with the GDPR, we do not knowingly collect or process data from individuals under the age of 18 without explicit parental consent.
11. Changes to this Policy
We may update this policy periodically to reflect changes in technology or law. Significant changes will be communicated via our website or email.