Last Updated: The 10th of April 2025
1. Introduction
REALTXY.COM ("we," "us," or "our") is an online real estate service based in Belgrade, Serbia, offering integrated real estate solutions, including:
- Real Estate as a Service (REaaP) – A purchasing model for buyers.
- Object as a Project (OaaP) – A selling model for property sellers.
We serve clients in Serbia, Hungary, Greece, Montenegro, Bosnia and Herzegovina, the EU, China, India, Vietnam, and the Russian Federation.
This Privacy Policy complies with:
- EU General Data Protection Regulation (GDPR) (for EU clients).
- Serbian Data Protection Law (if applicable).
- Other relevant national laws where we operate.
By using our services, you agree to this policy.
2. Data We Collect2.1. Personal Data Provided by You
- Identity & Contact Data: Full name, email, phone, address, passport/ID (for legal transactions).
- Financial & Transaction Data: Bank details, payment history (processed via PCI-DSS-compliant providers).
- Property & Preference Data: Purchase/sale history, investment criteria.
- Communications: Emails, support tickets, chat logs.
2.2. Automated Data Collection
- Technical Data: IP address, device type, browser, cookies (see Section 6).
- Usage Data: Pages visited, session duration (via Google Analytics with anonymization).
2.3. Data from Third Parties
- Real Estate Agents & Public Registries: Property listings, ownership verification.
3. Legal Basis & Purpose of Processing
We process data under:
Legal Basis | Purpose |
Contractual Necessity | To fulfill REaaP/OaaP agreements. |
Legal Obligation | Anti-money laundering (AML), tax compliance. |
Legitimate Interest | Fraud prevention, service improvement. |
Consent | Marketing (opt-in required for EU clients). |
4. Data Storage & Security
- EU-Based Servers: All data is stored in the European Union with strict access controls.
- Encryption: Data in transit (TLS 1.2+) and at rest (AES-256).
- Access Restrictions: Only authorized REALTXY.COM personnel can access data (role-based permissions).
- Retention Period:
- Transaction records: 10 years (for tax/legal compliance).
- Marketing data: Until consent withdrawal.
5. International Data Transfers
- EU → Non-EU (e.g., China, Russia): We use GDPR Article 46 safeguards (Standard Contractual Clauses or Binding Corporate Rules).
- Third-Party Processors: Subcontractors must comply with GDPR and Data Processing Agreements (DPAs).
6. Cookies & Tracking
We use:
- Essential Cookies: Session management.
- Analytics Cookies: Google Analytics (anonymized IPs).
- Marketing Cookies: Only with prior consent (EU clients).
Users can manage preferences via browser settings.
7. Your GDPR Rights
EU clients may:
✅ Access, correct, or delete their data.
✅ Restrict processing or object to direct marketing.
✅ Data portability (request a machine-readable copy).
✅ Lodge a complaint with a supervisory authority (e.g., Serbian Commissioner for Information of Public Importance).
Request method: Email
privacy@realtxy.com with proof of identity.
8. Children’s Privacy
We do not knowingly process data from users under 16.
9. Updates & Contact
- Policy Changes: Posted on our website; material changes notified via email.
- Contact:
- Email: privacy@realtxy.com