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Privacy Policy

Draft, under legal review

This document is a working draft. It has not yet been reviewed by a lawyer and some details, such as the named data controller, are not filled in yet. It is published so you can see the terms we intend to operate under. It is not yet our final policy.

Who we are

SmartDecision is an online platform built by licensed property consultants. It is not a registered company. Every property sale made through the platform is carried out by a consultant licensed in the market concerned. We introduce people buying property abroad to those consultants, and we run residency, golden visa and citizenship processes.

The controller of your personal data is:

Platform
SmartDecision, an online platform built by licensed property consultants
Privacy enquiries
admin@smartdecisionproperties.com

We do not operate physical offices. All contact takes place through the channels listed on this website.

What this policy covers

This policy explains what personal data we collect when you use this website, why we collect it, who we share it with, and what rights you have.

The most important thing to understand is in the section headed “Sharing your data with property consultants”. Please read that section before submitting an enquiry.

What we collect

When you submit an enquiry or request an appointment:

  • Name
  • Email address
  • Telephone number
  • Country you are interested in
  • What you are trying to achieve (investment, relocation, holiday home, residency, resale)
  • Budget range, if you choose to provide it
  • Anything you write in the message field
  • The page you were on when you submitted
  • The language you were using

Budget is optional. You can complete an enquiry without it.

When you create an account:

  • Name and email address
  • Password, stored in hashed form. We never see or store your password in readable form
  • Properties you save
  • Searches you save
  • Enquiries you have made

Automatically, when you browse:

  • IP address
  • Browser and device type
  • Pages viewed and time spent
  • Referring website
  • Approximate location derived from your IP address, used to set your default currency and to show you the right contact details

Some of this is collected only if you consent to analytics or marketing cookies. See our Cookie Policy.

We do not collect payment card details, bank details, passport or identity document copies, or financial statements. We are not a party to your purchase transaction and we do not need this information. If anyone claiming to represent us asks you for these through this website, do not provide them and contact us.

Why we use it, and on what legal basis

What we doWhyLegal basis
Respond to your enquiryTo answer the question you askedSteps taken at your request before entering a contract
Match you with a property consultantThis is the service you asked forSteps taken at your request; our legitimate interest in operating our business
Share your enquiry with a selected consultantSo they can advise youSteps taken at your request; our legitimate interest
Run and secure the websiteTo keep the service working and safeOur legitimate interest
Understand how the site is usedTo improve itYour consent, through analytics cookies
Send you marketingTo tell you about relevant properties or guidanceYour consent
Show advertising on other sitesTo reach people who may be interestedYour consent, through marketing cookies
Keep records of enquiries and consentsTo meet legal obligations and defend claimsLegal obligation; our legitimate interest

Where we rely on legitimate interest, we have considered whether our interest is outweighed by your rights. You can object to this processing at any time using the contact details above.

Sharing your data with property consultants

This is central to how our service works, and you should understand it before you enquire.

When you submit an enquiry, we review it ourselves first. We then select a property consultant in the relevant market and pass your enquiry to that person so they can contact you.

That consultant may be:

  • A consultant employed by SmartDecision Properties, or
  • An independent property consultant or agency we work with in that market

What we share: your name, contact details, the market you are interested in, your stated goal, your budget range if you provided one, and your message.

When we share it: only after we have selected a consultant for you. Consultants cannot browse enquiries, cannot request particular clients, and cannot advertise on this website. Nobody sees your enquiry until we have decided who is right for it.

What happens then: the consultant becomes an independent controller of your data. They will contact you directly. Their own privacy policy applies to how they handle your data from that point, alongside ours. We require every partner to have appropriate data protection arrangements in place and to use your data only for the purpose we passed it to them for.

If you do not want this: tell us in the message field, or contact us before enquiring, and we will discuss your enquiry with you without passing it on. Please note we may not be able to provide the service in that case.

Who else we share data with

RecipientPurpose
Hosting and infrastructure providersRunning the website
Email service providersSending you confirmations and replies
Customer relationship management systemManaging enquiries
Analytics providersUnderstanding site usage, only with your consent
Advertising platformsShowing relevant advertising, only with your consent
Professional advisersLegal and accounting advice where necessary
AuthoritiesWhere we are legally required to disclose

We do not sell your personal data.

International transfers

Our licensed consultants are located in the countries we work in: the United Arab Emirates, the United Kingdom, Türkiye, Greece, Hungary, Portugal and Panama.

Greece, Hungary and Portugal are in the European Union, and the United Kingdom has a data protection framework recognised in Europe. The United Arab Emirates, Türkiye and Panama do not currently have an adequacy decision from the European Commission or the UK government.

Where we transfer your data to a consultant or service provider outside the UK or European Economic Area, we put appropriate safeguards in place. You can ask us for details of the safeguards that apply to your data using the contact details above.

How long we keep it

DataRetention
Enquiries that did not lead to a purchase24 months from last contact
Enquiries that led to a purchase7 years, for legal and tax record keeping
Account dataUntil you delete your account, then 30 days
Consent records7 years, as evidence that consent was given
Analytics data26 months
Marketing preferencesUntil you withdraw consent, plus a record that you did

Your rights

Depending on where you are, you have the right to:

  • Ask what data we hold about you and get a copy
  • Have inaccurate data corrected
  • Have your data deleted in certain circumstances
  • Restrict how we use your data
  • Receive your data in a portable format
  • Object to processing based on legitimate interest
  • Withdraw consent at any time, including for marketing and cookies
  • Complain to a data protection authority

To exercise any of these, contact us using the details above. We will respond within one month.

If your data has already been passed to a property consultant, you may also need to contact them directly for data they hold. We will tell you who they are and how to reach them.

Complaints: you can complain to the data protection authority where you live or work, or where you believe the problem arose. In the UK that is the Information Commissioner's Office. In the European Union it is the authority of your member state. In Türkiye it is the Kişisel Verileri Koruma Kurumu.

Security

We use encryption in transit, access controls, and hashed password storage. No system is completely secure, and we cannot guarantee absolute security. If a breach occurs that is likely to affect your rights, we will notify you and the relevant authority as required by law.

Children

This service is not directed at people under 18 and we do not knowingly collect their data.

Changes

We may update this policy. The date at the top shows when it was last changed. If we make a significant change, we will tell you.

Questions about this document

Talk to us