Version: 1.0
Effective date: 20.10.2026
Last updated: 20.10.2026
1. Who is the controller of personal data?
The controller of personal data collected through the imotigreece.com website (the „Site“) is:
„EUVEXA“ LTD
UIC: 203770780
Registered office and management address: Bulgaria, Sofia (1618), Ovcha kupel district, Ovcha kupel quarter, Lyubliana Str., 8
Manager: Krasimir Angelov Ivanov
Email for contact regarding personal data protection: privacy@imotigreece.com
This Policy applies to all personal data processed through the Site, including through the KoTS feature (available at imotigreece.com/kots/ and via QR codes in partner establishments), as well as through contact forms, email notification subscriptions and other functionalities.
Important: „EUVEXA“ LTD is not a real estate broker, does not sell properties and is not a party to real estate transactions. The Site is an advertising platform on which licensed Greek brokers advertise their properties. The processing of personal data under this Policy is related only to the administration of the Site and the advertising platform, and not to the execution of real estate transactions.
2. What personal data do we collect and why?
2.1. Data provided by you when using KoTS (client)
When you scan a QR code in a partner establishment and fill in the form (as a buyer or seller of property), we collect:
| Category | Fields | Purpose | Legal basis |
|---|---|---|---|
| Identification | Name | To contact you and personalize correspondence | Art. 6, para. 1, point (b) GDPR (pre-contractual relations — in relation to the advertising service) |
| Contact | Phone, email (optional), preferred channel | To contact us regarding the enquiry | Art. 6, para. 1, point (b) GDPR |
| Property/search data | Region, area, category, budget, term, financing, area, bedrooms, floor, condition, desired price, notes | To provide a relevant service (connection with a licensed broker) | Art. 6, para. 1, point (b) GDPR |
| Marketing consent | Opt-in for receiving marketing communications | Sending offers and news (only with consent) | Art. 6, para. 1, point (a) GDPR |
| Technical | IP address (hashed), date/time | Security, fraud prevention | Art. 6, para. 1, point (e) GDPR (legitimate interest) |
Mandatory fields: Name and phone. Without them we cannot process the enquiry. Email is mandatory only if you choose „Email“ as your preferred channel.
Voucher data: Upon a completed transaction (marked by the Site administrator), a voucher is issued to you. We store your name, email (if provided) and voucher data (code, value, currency, dates, status). Basis: performance of contractual relations (Art. 6, para. 1, point (b) GDPR) — the voucher is part of the counter-performance promised by us under the advertising service. The voucher is not related to a real estate transaction and does not represent a commission or remuneration for brokerage services.
2.2. Data collected through other Site features
| Feature | Data | Purpose | Basis |
|---|---|---|---|
| Contact form | Name, email, content of the message | Responding to an enquiry | Art. 6, para. 1, point (b) GDPR |
| „Email notification“ (property alerts) | Email, preferences for property type/budget | Sending personalized alerts | Art. 6, para. 1, point (a) GDPR |
| Newsletter subscription (if available) | Marketing communications | Art. 6, para. 1, point (a) GDPR |
2.3. Data of employees and owners of partner establishments (KoTS)
For employees: name, position, code, hashed token, points, last login. For owners: name, email, WordPress username, password hash. Basis: performance of the contract with the establishment (Art. 6, para. 1, b. „b“ GDPR).
3. Who has access to your data?
| Recipient | What data | Purpose |
|---|---|---|
| „YUVEXA“ EOOD (administrator) | Full access | Website and advertising platform management |
| Licensed Greek broker (only with your explicit consent or upon submitting an inquiry through KoTS) | Name, phone, email, search criteria/property data | Contacting you regarding the search/sale of the property |
| Owner of a partner establishment (KoTS) | Only voucher code, value and status. No name, phone, email, notes. | Reporting of issued vouchers |
| Employee of the establishment (KoTS) | No personal data of clients | Motivation (own points) |
| Hosting provider | Technical access (processor under Art. 28 GDPR) | Infrastructure and support |
We do not sell or provide personal data to third parties for marketing purposes. „YUVEXA“ EOOD does not carry out brokerage activity and does not receive commissions from property transactions. The licensed brokers who advertise on the Website are separate administrators of the personal data they process in the course of their brokerage activity.
4. How long do we keep the data?
| Category | Term |
|---|---|
| KoTS leads (forms) | 24 months from submission, after which they are anonymized (name, phone, email, notes, IP hash are deleted) |
| KoTS vouchers | Until expiry + 24 months, after which they are anonymized (recipient's name/email are deleted) |
| KoTS employees | Until termination of the contract + 12 months |
| KoTS owners (WP profiles) | Until closure by administrator |
| Contact forms and email notifications | Until withdrawal of consent or 24 months from the last interaction |
| Server logs (security) | 30 days |
5. Your rights
Under the GDPR you have the right to: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), objection (Art. 21) and withdrawal of consent (Art. 7, para. 3) at any time, without affecting the lawfulness of processing prior to the withdrawal.
To exercise your rights: privacy@imotigreece.com. We respond within up to 1 month.
Right to complain: Commission for Personal Data Protection (CPDP), 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd., website: www.cpdp.bg, email: kzld@cpdp.bg.
6. Automated decision-making (KoTS)
KoTS calculates a score for each inquiry based on the data provided by you (budget, term, financing, category). The result is used only for internal qualification and status determination. It does not lead to legal consequences and does not deny you access to the service. Under Art. 22 GDPR you have the right to request human intervention.
7. Cookies
The Website uses:
| Cookie | Category | Purpose | Term |
|---|---|---|---|
wordpress_logged_in_* |
Strictly necessary | Session for owner of establishment (KoTS) | 14 days |
kots_staff_session |
Strictly necessary | Session for serving staff (KoTS) | 7 days |
kots_owner_confirm |
Strictly necessary | One-time owner access confirmation | Session |
_ga, _ga_NPRZ140PNH |
Analytics | Traffic analytics (Google Analytics 4 via MonsterInsights) | 2 years |
KoTS does not use analytics or tracking cookies in the client-side part. The Site's analytics cookies are set only after consent through the cookie banner. Details — in Cookie Policy.
8. Security
We apply technical and organizational measures: hashing of tokens and IP, HTTPS, restricted access, regular archiving, principle of least privilege. In the event of a security breach affecting your rights, we will notify you within 72 hours where applicable.
9. Amendments
The current version is available at https://imotigreece.com/politika-za-poveritelnost/. In the event of material changes, we will publish a notice and, if necessary, we will seek renewed consent.