Privacy Policy

1. INTRODUCTION

Papaya Property Limited ("we", "us", "our", or "Company") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our website papaya-property.com (the "Platform").

This Privacy Policy applies to all users worldwide and complies with:

GDPR (General Data Protection Regulation) - European Union
PDPA (Personal Data Protection Act) - Thailand
PIPL (Personal Information Protection Law) - China
APPI (Act on the Protection of Personal Information) - Japan
Other applicable data protection laws

2. DATA CONTROLLER INFORMATION

Company Name: Papaya Property Limited

Registration: Hong Kong SAR

Director: Gleb Kozhemyako

Registered Address: Unit 1603, 16th Floor, The L. Plaza, 367-375 Queen's Road Central, Sheung Wan, Hong Kong

Contact for Privacy Matters:

Email: privacy@papaya-property.com

General Contact: qa@papaya-property.com

Website: https://papaya-property.com

3. WHAT INFORMATION WE COLLECT

3.1 Information You Provide Directly

During Registration:

Email address (required)
Phone number (required)
Password (if not using OAuth)
Name (optional, may be collected from OAuth providers)

For Affiliate/Partner Program:

Full name
Payment details (bank account information, PayPal, etc.)
Tax information (if required by jurisdiction)
Business information (if applicable)

3.2 Information Collected Automatically

Technical Information:

IP address
Browser type and version
Device type and operating system
Time zone setting and location (general)

Cookies and Tracking Technologies:

Session cookies
Analytics cookies (Google Analytics)
Marketing cookies (Facebook Pixel)
Remarketing tags

3.3 Information from Third-Party Sources

OAuth Authentication Providers:

When you register or log in using third-party services, we may receive:

Google: Name, Email address, Profile picture, Google ID
Facebook: Name, Email address, Profile picture, Facebook ID
WeChat: WeChat ID, Nickname, Profile picture

4. HOW WE USE YOUR INFORMATION

4.1 Legal Bases for Processing (GDPR)

We process your personal data based on the following legal grounds:

Consent: When you give explicit consent (e.g., marketing communications, cookies)
Contract Performance: To provide services you requested (account creation, affiliate payments)
Legitimate Interests: To improve our services, prevent fraud, ensure security
Legal Obligation: To comply with legal requirements (tax, AML, KYC)

4.2 Purposes of Data Processing

Provide and Maintain Services:

Create and manage your account
Authenticate your identity
Display property listings relevant to you
Process affiliate commissions and payments
Communicate about your account or transactions

Marketing and Communications:

Send property updates and newsletters (with consent)
Display targeted advertisements
Conduct remarketing campaigns
Send promotional offers

5. HOW WE SHARE YOUR INFORMATION

5.1 We Do NOT Sell Your Personal Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

5.2 Service Providers and Partners

We share data with trusted third parties who help us operate:

Analytics and Marketing:

Google Analytics (Google LLC, USA)
Facebook Pixel (Meta Platforms, USA)
Remarketing service providers

Payment Processors:

Banks and financial institutions
Payment gateways (for affiliate payouts)

6. INTERNATIONAL DATA TRANSFERS

As a global platform, your data may be transferred to and processed in countries outside your residence, including Hong Kong (our headquarters), United States (analytics and marketing services), and European Union (hosting infrastructure).

We ensure appropriate safeguards for international transfers:

For EU/EEA Users (GDPR): Standard Contractual Clauses (SCCs)
For China Users (PIPL): Government-approved mechanisms, Security assessments
For Thailand Users (PDPA): Consent-based transfers
For Japan Users (APPI): Appropriate and necessary measures

7. DATA RETENTION

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

Active Accounts: Duration of account + 3 years after closure
Transaction records: 7 years (legal/tax requirements)
Affiliate Program: Payment records 7 years (tax compliance)
Marketing data: Until consent withdrawal + 6 months

8. YOUR PRIVACY RIGHTS

8.1 Rights Under GDPR (EU/EEA Users)

Right to Access: Obtain confirmation and copies of your data
Right to Rectification: Correct inaccurate or incomplete data
Right to Erasure: Request deletion of your data
Right to Data Portability: Receive your data in a structured format
Right to Object: Object to processing based on legitimate interests
Right to Lodge a Complaint: File complaints with supervisory authorities

8.2 How to Exercise Your Rights

To exercise any of these rights, contact us:

Email: info@papayaproperty.com

Subject Line: "Privacy Rights Request - [Type of Request]"

Response Time:

GDPR: Within 1 month (may extend to 3 months for complex requests)
PIPL (China): Within 15 days (may extend to 60 days)
PDPA (Thailand): Within 30 days
APPI (Japan): Without undue delay

9. COOKIES AND TRACKING TECHNOLOGIES

Cookies are small text files stored on your device when you visit our Platform. We use cookies for functionality, analytics, and marketing. For detailed information, see our Cookie Policy.

Types of Cookies We Use:

Essential Cookies (Required): Authentication and security, Session management
Analytics Cookies (Optional): Google Analytics, Visitor statistics
Marketing Cookies (Optional): Facebook Pixel, Remarketing tags

10. SECURITY MEASURES

We implement industry-standard security measures:

Encryption in transit (SSL/TLS)
Encryption at rest for sensitive data
Secure authentication (OAuth 2.0)
Firewalls and intrusion detection
Regular security audits
Access controls (need-to-know basis)

11. CHILDREN'S PRIVACY

Our Platform is NOT intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

If we become aware that we have collected data from a person under 18, we will delete such information promptly and terminate the account.

12. MARKETING COMMUNICATIONS

With your consent, we may send:

Property updates and new listings
Newsletters
Promotional offers
Affiliate program updates

Opt-Out: You can unsubscribe from marketing emails at any time by:

Clicking "unsubscribe" in any marketing email
Updating preferences in your account settings
Emailing info@papayaproperty.com

13. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices, legal or regulatory changes, new features or services, and feedback from users.

Material Changes: We will notify you by:

Email to your registered address
Prominent notice on the Platform
Update notification when you log in

14. CONTACT INFORMATION

General Privacy Questions:

Email: info@papayaproperty.com

Data Subject Requests:

Email: info@papayaproperty.com

Subject: "Privacy Rights Request"

General Support:

Email: info@papayaproperty.com

Company Details:

Papaya Property Limited

Registration: Hong Kong SAR

Director: Gleb Kozhemyako

Website: https://papayaproperty.com

Registered Address:

Unit 1603, 16th Floor, The L. Plaza

367-375 Queen's Road Central

Sheung Wan, Hong Kong

Bank Details:

DBS Bank (Hong Kong) Limited

Account: 796503525

SWIFT: DHBKHKHH

15. ACKNOWLEDGMENT

By using our Platform, you acknowledge that:

You have read and understood this Privacy Policy
You consent to the collection and processing of your data as described
You understand your rights and how to exercise them
You are at least 18 years of age