Privacy Policy for Property Requests
Pay Per Action Ltd · Last updated: 2 July 2026
This Policy covers property requests submitted through our advertising and lead forms on Meta, TikTok and our landing pages. If you are a business client, partner or visitor of our corporate website, see our Website Privacy Policy.
In short. We run property advertising campaigns and help people find real estate. When you submit a request through one of our forms (including forms on Facebook, Instagram or TikTok), we collect your contact details and your answers about what you are looking for. We may contact you to confirm your request, and we pass your details to one or more real estate developers so they can offer you suitable properties. Developers pay us for this service. This Policy explains the details and your rights.
1. Who we are
Pay Per Action Ltd ("PayPerAction", "we", "us") is a lead generation company registered in the Republic of Cyprus, with its registered office at 20 Charalambou Mouskou, Paphos 8010, Cyprus.
We are the data controller for the personal data described in this Policy. You can reach us at request@payperaction.eu.
2. What this Policy covers
This Policy applies to personal data we collect through:
- our website payperaction.eu and our campaign websites, including mycyprushome.eu;
- lead forms and quizzes we run on advertising platforms, including Meta platforms (Facebook, Instagram) and TikTok ("lead forms");
- landing pages and quiz pages operated by us;
- phone calls, emails and messenger conversations between you and our team after you submit a request.
Meta and TikTok also process your data when you use their apps and forms. They do so as separate, independent controllers under their own policies: Meta Privacy Policy, TikTok Privacy Policy.
3. What personal data we collect
Data you give us in a lead form or quiz
- your name, phone number and email address;
- your answers about the property you are looking for, for example: preferred number of rooms or bedrooms, budget range, expected purchase timeline, purpose of purchase (own use or investment), preferred location, and other preferences you choose to share.
Data we receive from the advertising platform
- the contact details the platform pre-fills into the form from your profile (you can edit them before submitting);
- campaign metadata: which ad and form you responded to, and the date and time of submission;
- a record of the consent you gave in the form.
Data created when we communicate with you
- notes of our phone or messenger conversations, including confirmation of your interest and whether your request matches the criteria agreed with our partners;
- call recordings, if and where we record calls. We will always tell you at the start of a call if it is being recorded, and on what basis.
Data collected on our website
- technical data such as IP address, browser type, device and operating system, pages visited and interactions, collected through cookies and similar technologies (see section 12).
We do not ask for and do not collect payment card details, bank account numbers or other financial account information.
4. Why we use your data and on what legal basis
| Purpose | What we do | Legal basis (GDPR) |
|---|---|---|
| Handling your request | We receive your form, contact you by phone, email or messenger to confirm your details and clarify what you are looking for. | Your consent (Art. 6(1)(a)), given when you submit the form. |
| Matching and referral to developers | We use your answers to select one or more suitable real estate developers and pass your contact details and preferences to them so they can offer you properties. If the first developer cannot serve your request, we may pass your details to another developer matching your criteria. | Your consent (Art. 6(1)(a)), given when you submit the form. |
| Service fee settlement with partners | Developers pay us for referrals. To calculate our remuneration, we keep records of which requests we referred and receive limited feedback from the developer on the status of your request (for example, whether contact took place or a purchase was completed). We do not receive your payment details. | Our legitimate interest in operating and billing our services (Art. 6(1)(f)). |
| Marketing communications | If you separately agree, we may send you other relevant property offers and updates. You can opt out at any time. | Your consent (Art. 6(1)(a)), given via a separate opt-in. |
| Quality, security and record keeping | We keep records of requests, consents and communications to maintain service quality, prevent fraud and abuse, and to establish, exercise or defend legal claims. | Our legitimate interest (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) where records are required by law. |
| Accounting and tax compliance | We retain transaction-related records as required by Cyprus law. | Legal obligation (Art. 6(1)(c)). |
Providing your data is voluntary. However, if you do not provide your contact details or do not consent to the referral, we will not be able to process your property request.
5. Who we share your data with
Real estate developers and property sellers
This is the core of our service. We share your contact details and property preferences with licensed real estate developers and property sellers that are active in the location you indicated in your request, and with their authorised sales teams. Depending on your request, this may be one developer or, if the first developer cannot serve your request, another developer matching your criteria.
You have the right to know exactly who received your data. At any time, you can ask us to name the specific company or companies we passed your details to. Contact us at request@payperaction.eu and we will tell you.
Service providers (processors)
We use carefully selected providers who process data on our behalf and under our instructions: CRM and database hosting, cloud infrastructure, telephony and messaging services, and analytics. They are bound by data processing agreements and may not use your data for their own purposes.
Advertising platforms
Meta and TikTok process your data as independent controllers when you interact with their apps and lead forms, including keeping records of your form submissions and consents on their side.
Authorities and legal requirements
We may disclose personal data where required to comply with applicable law, a court order or a lawful request of a competent authority, or to protect our rights and property.
We do not sell your data to data brokers and do not share it with anyone other than as described in this Policy.
6. What happens after we pass your details to a developer
Once a developer receives your details, it processes them as an independent data controller under its own privacy policy, for example to contact you and offer you properties. From that point, the developer is responsible for its own processing, and you can exercise your privacy rights directly with the developer as well as with us.
We remain the controller of the records we keep about your request, and we remain responsible for the lawfulness of the transfer itself. If you want to know which developer received your data and how to contact them, ask us at any time.
7. How long we keep your data
- Request (lead) data, including your quiz answers and communication notes: up to 36 months from our last interaction with you, after which it is deleted or irreversibly anonymised, unless you withdraw your consent earlier (see section 9).
- Consent records and transaction-related records (which request was referred to which partner, and related billing): up to 6 years, in line with Cyprus accounting, tax and limitation-period requirements.
- Call recordings, where made: up to 12 months, unless a longer period is needed for a specific dispute.
- Website analytics data: according to the retention settings of the relevant tool (see section 12).
8. International data transfers
We are based in Cyprus and primarily process data within the European Economic Area. Some of our service providers may process data outside the EEA. In such cases, we rely on safeguards recognised by the GDPR, such as adequacy decisions of the European Commission or Standard Contractual Clauses, and we take supplementary measures where needed.
9. Your rights
Under the GDPR you have the right to:
- access your personal data and receive a copy of it, including the identity of the recipients we passed it to;
- rectify inaccurate or incomplete data;
- erase your data ("right to be forgotten") in the circumstances set out in Art. 17 GDPR;
- restrict processing in the circumstances set out in Art. 18 GDPR;
- data portability: receive the data you provided to us in a structured, commonly used, machine-readable format;
- object to processing based on our legitimate interests, and to direct marketing at any time;
- withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
To exercise any of these rights, email us at request@payperaction.eu. We will respond within one month, as required by the GDPR.
If you withdraw your consent, we will stop the related processing and will ask the developer(s) that received your data from us to be informed of your withdrawal. Note that the developer's own processing after the transfer is governed by its own legal bases and policy.
You also have the right to lodge a complaint with a supervisory authority. Our lead authority is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus (dataprotection.gov.cy). You may also complain to the authority of your country of residence.
10. Matching and profiling
We use your quiz answers (such as budget range, preferred number of rooms and timeline) to select suitable developers and properties for your request. This is a simple matching process. We do not make automated decisions about you that produce legal effects or similarly significantly affect you within the meaning of Art. 22 GDPR.
11. How we protect your data
We apply appropriate technical and organisational measures to protect your personal data, including encrypted connections, access controls, and role-based access to our CRM. Access to lead data is limited to staff and contractors who need it to perform the services described in this Policy. We review and improve these measures regularly.
12. Cookies and similar technologies
Our website uses cookies and similar technologies (including Google Tag Manager and advertising pixels such as the Meta Pixel) to operate the site, measure the effectiveness of our campaigns and, with your consent, to personalise advertising. Advertising and analytics cookies are used only with your consent, which you can give or refuse via the cookie banner and change at any time.
Tracking technologies of Meta and other providers may collect information about your activity on our website and other websites to measure ad performance and target advertising. You can learn more and opt out via your platform settings: Meta ad preferences, TikTok privacy settings.
You can also configure your browser to refuse cookies. Instructions: Google Chrome, Mozilla Firefox, Safari, Chrome for Android, Safari iOS.
13. Children
Our services and advertising are directed at adults. We do not knowingly collect personal data from anyone under 18. If you believe a minor has submitted data to us, contact us and we will delete it.
14. Changes to this Policy
We may update this Policy from time to time. The current version is always available on this page, with the date of the last update shown at the top. For material changes affecting how we use your data, we will take reasonable steps to inform you.
15. Contact us
Pay Per Action Ltd
20 Charalambou Mouskou, Paphos 8010, Cyprus
Email: request@payperaction.eu