Privacy Policy

Effective Date: January 2026

Thallo (“Thallo”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Cyprus Law Providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018), and any applicable amendments or related legislation.

This Privacy Policy explains how personal information is collected, used, stored, and protected when you visit the Thallo website, communicate with us, request leasing information, or otherwise interact with our services.

1. Data Controller

The controller responsible for your personal data is:

Thallo
Larnaca, Cyprus
Email: hello@thallo.com
Telephone: +357 XX XXX XXX

For the purposes of GDPR, Thallo acts as the data controller regarding all personal information collected through this website and associated communication channels.

2. Information We Collect

We may collect and process the following categories of personal information:

Information You Provide Directly

  • Full name
  • Email address
  • Telephone number
  • Company name
  • Job title
  • Information submitted through contact or viewing request forms
  • Any information voluntarily included in communications with us

Information Collected Automatically

When using our website, certain technical information may be collected automatically, including:

  • IP address
  • Browser type and version
  • Device identifiers
  • Operating system
  • Referral source
  • Pages visited
  • Time spent on the website
  • Geographic location data (approximate)
  • Website interaction analytics

Cookies & Tracking Technologies

Our website may use:

  • Essential cookies
  • Analytics cookies
  • Performance cookies
  • Marketing and advertising cookies
  • Third-party integrations

A separate Cookie Policy may apply.

3. Purpose of Processing

Your personal data may be processed for the following purposes:

  • Responding to enquiries and viewing requests
  • Providing leasing and availability information
  • Communicating regarding the Thallo development
  • Managing prospective tenant relationships
  • Sending newsletters and marketing communications where consent has been provided
  • Improving website functionality and user experience
  • Monitoring website performance and analytics
  • Protecting website security and preventing misuse
  • Complying with legal and regulatory obligations
  • Preparing future leasing discussions and commercial communications

4. Legal Basis for Processing

We process personal data under one or more of the following lawful bases:

Consent

Where you voluntarily submit information through forms or subscribe to marketing communications.

Legitimate Interests

For the operation, improvement, security, and commercial management of the Thallo project and website.

Legal Obligation

Where processing is necessary to comply with applicable laws, regulations, or lawful requests.

Pre-Contractual Measures

Where information is necessary in connection with potential leasing discussions or commercial negotiations.

5. Marketing Communications

Where you have provided consent, Thallo may send:

  • Project updates
  • Leasing announcements
  • Availability notices
  • Development news
  • Marketing communications related to the project

You may unsubscribe at any time through the unsubscribe link included in communications or by contacting us directly.

6. Data Sharing

Your information may be shared with carefully selected third parties where necessary, including:

  • Website hosting providers
  • CRM and email communication platforms
  • IT service providers
  • Analytics providers
  • Legal and professional advisers
  • Marketing service providers
  • Regulatory or governmental authorities where legally required

All third parties are required to maintain appropriate confidentiality and security standards.

We do not sell personal data.

7. International Transfers

Where personal data is transferred outside the European Economic Area (EEA), appropriate safeguards will be implemented in accordance with GDPR requirements, including:

  • European Commission adequacy decisions
  • Standard Contractual Clauses (SCCs)
  • Equivalent lawful transfer mechanisms

8. Data Retention

Personal data will only be retained for as long as reasonably necessary for:

  • the purposes outlined in this Privacy Policy,
  • legal and regulatory obligations,
  • legitimate business interests,
  • dispute resolution,
  • contractual or pre-contractual matters.

Certain records may be retained for up to seven (7) years where required under applicable tax, accounting, or legal obligations.

9. Security Measures

Thallo implements appropriate technical and organisational security measures designed to protect personal data, including:

  • Secure hosting infrastructure
  • Access controls
  • Encryption technologies
  • Firewalls and malware protection
  • Internal confidentiality procedures
  • Restricted personnel access

However, no online platform or transmission method can be guaranteed to be entirely secure.

10. Your Rights

Under GDPR, you may have the right to:

  • Access your personal data
  • Correct inaccurate information
  • Request erasure of data
  • Restrict processing
  • Object to processing
  • Withdraw consent
  • Request data portability
  • Lodge a complaint with the Cyprus Commissioner for Personal Data Protection

Requests may be submitted to:
hello@thallo.com

11. Third-Party Links

This website may contain links to external websites or third-party platforms. Thallo is not responsible for the privacy practices, content, or policies of such external websites.

12. Project Disclaimer

All visuals, renderings, specifications, floorplans, dimensions, amenities, technical features, sustainability targets, completion timelines, and development information displayed on this website are indicative only and subject to change without prior notice.

Nothing contained on this website constitutes:

  • a contractual commitment,
  • legal representation,
  • leasing guarantee,
  • offer for lease,
  • or binding obligation.

Final specifications and leasing terms shall be governed exclusively by executed legal agreements.

13. Children’s Privacy

This website is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors.

14. Changes to this Privacy Policy

Thallo reserves the right to amend or update this Privacy Policy at any time without prior notice. Updated versions will be published on this website with a revised effective date.

15. Contact Information

For privacy-related enquiries:

Thallo
Larnaca, Cyprus
Email: hello@thallo.com
Telephone: +357 XX XXX XXX