Privacy Notice – Vehicle Access Control at Sunset Gardens

Effective Date: 1 July 2025

This Privacy Notice explains how personal data will be collected and processed for the purpose of managing vehicle access through the automatic barrier system at Sunset Gardens, a private residential community in Limassol, Cyprus.

1.Who is responsible for your data?
Data Controller: Imperio Operations Limited
Contact Email: gdpr@imperio-group.com

2. What personal data do we collect and why?
We collect and process the following personal data to allow secure and regulated access to the residential premises:
- Full name
- Apartment number
- Vehicle license plate number(s) (up to two per unit)
- Email address
- Phone number

Purpose: To allow registered residents and their vehicles to access the community via the automatic entrance barrier system.

3. What is the legal basis for processing your data?
The processing is based on:

- Legitimate Interest (GDPR Article 6(1)(f)) – for the protection of property, access control, and safety of residents; and
- Consent (GDPR Article 6(1)(a)) – explicitly given by residents via the registration form for this specific purpose.

4. Who will have access to your data?
Your data will be accessible only to:

• Our authorized system installation contractor, solely for the purpose of configuring maintaining, and resolving any issues with the vehicle access control system. The contractor is bound by a Data Processing Agreement and is only permitted to access data when necessary for technical support or fault resolution.
• The Sunset Gardens property management team, for the ongoing operation and maintenance of the access control system. Access is restricted to designated personnel responsible for resident services and security.

Your data will not be shared with any other third party or used for any purpose unrelated to access control.

5. How long do we keep your data?
We retain your personal data for the minimum period necessary to fulfill its intended purpose:

• The vehicle plate data you provide will be retained by the property management office for as long as you are a resident and require access to the community via the barrier system.
• If you move out or notify us that your vehicle details have changed, your data will be updated or deleted accordingly.
• The contractor will have ongoing, secure access only for system maintenance purposes and will not store or extract personal data outside the access system. All access is logged and monitored.
• We review access control data on an annual basis to ensure accuracy and necessity.
  

6. What are your rights?
You have the right to:
- Access your data
- Request correction of incorrect data
- Request deletion (where applicable)
- Object to or restrict processing

To exercise your rights, contact us at: gdpr@imperio-group.com

7. How is your data protected?
We implement appropriate technical and organizational measures to safeguard your personal data, including:
- Access restrictions
- Secure data storage
- Contractor confidentiality obligations

8. Questions or complaints?
If you have concerns or questions about how we process your data, please contact us at gdpr@imperio-group.com.

If you're not satisfied with our response, you may contact the Office of the Commissioner for Personal Data Protection (Cyprus): https://www.dataprotection.gov.cy

This notice supplements the general Imperio Group Privacy Policy: https://imperio-group.com/website-privacy-notice/