Last updated: 21 July 2026

This Privacy Policy explains how AFS Agency collects, uses, stores and protects personal data when you visit afs.investments, submit an enquiry, request apartment information, arrange a property viewing or otherwise communicate with us regarding Garden Hill Residence.

We are committed to processing personal data lawfully, fairly and transparently in accordance with applicable data protection legislation, including Albanian Law No. 124/2024 “On Personal Data Protection” and, where applicable, the General Data Protection Regulation of the European Union.

1. Data Controller

The controller responsible for processing your personal data is:

Legal entity: AFS Agency / [insert registered legal company name]
Project: Garden Hill Residence
Registered address: [insert registered business address]
Project location: Arapaj, Albania
Email: AFSAGENCY@GMAIL.COM
Phone / WhatsApp: +355 68 449 9944

For any questions regarding this Privacy Policy or the use of your personal data, please contact us using the details above.

2. Personal Data We Collect

Depending on how you use the website and communicate with us, we may collect the following categories of personal data.

Information you provide directly

This may include:

• your name;
• telephone number;
• email address;
• preferred method of communication;
• information included in your message or enquiry;
• apartment preferences, including preferred size, layout, floor or budget;
• preferred date and format for a property viewing;
• information necessary to arrange an online or in-person consultation;
• any other information you voluntarily provide.

Please do not submit sensitive personal information through the website forms unless we specifically request it and have a lawful reason to process it.

Information collected automatically

When you visit the website, certain technical information may be collected automatically, including:

• IP address;
• browser type and version;
• device type and operating system;
• approximate location based on IP address;
• pages visited and time spent on the website;
• date and time of access;
• referring website;
• technical logs, error reports and security information;
• cookie identifiers and similar technologies.

Some of this information may be collected by our hosting, security, analytics or website service providers.

Communication data

When you contact us by email, telephone, WhatsApp or another communication platform, we may process:

• your contact details;
• the date and time of communication;
• the content of your message;
• information required to respond to your enquiry;
• records of consultations, viewings and follow-up communication.

3. How We Use Your Personal Data

We may use your personal data to:

• respond to apartment enquiries;
• send available floor plans, prices and property information;
• arrange online or in-person property viewings;
• provide consultations regarding the purchase process;
• contact you regarding apartments that match your preferences;
• manage apartment reservation and purchase requests;
• prepare documents and take steps before entering into an agreement;
• maintain records of enquiries and client communications;
• provide customer support;
• improve the website and its content;
• understand how visitors use the website;
• maintain website functionality, security and fraud prevention;
• comply with legal, accounting and regulatory obligations;
• establish, exercise or defend legal claims;
• send promotional communications where you have provided consent or where otherwise permitted by law.

We will not use your personal data for purposes that are incompatible with the purposes described in this Privacy Policy.

4. Legal Bases for Processing

We process personal data only where there is a valid legal basis.

Depending on the circumstances, processing may be based on:

Your consent

We may rely on your consent when you:

• submit a contact or viewing request;
• agree to receive promotional communications;
• accept optional analytics or marketing cookies;
• voluntarily provide information for a specific purpose.

You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Steps taken at your request before entering into a contract

We may process your information when you ask us to:

• provide apartment prices or floor plans;
• arrange a viewing;
• reserve an apartment;
• explain purchase terms;
• prepare documents related to a potential transaction.

Performance of a contract

Where you purchase or reserve an apartment, we may process your data as necessary to perform our obligations under the relevant agreement.

Compliance with legal obligations

We may process and retain information where required by applicable property, tax, accounting, anti-fraud, notarial or other legal requirements.

Legitimate interests

We may process data where necessary for our legitimate business interests, provided that these interests do not override your rights and freedoms.

These interests may include:

• responding to enquiries;
• managing client relationships;
• improving our services;
• protecting the website;
• preventing misuse or fraud;
• maintaining business records;
• establishing or defending legal claims.

5. Contact Forms and Viewing Requests

When you complete a form on the website, we use the information you provide to respond to your request and provide information about Garden Hill Residence.

Required fields will be marked accordingly. Without certain information, such as your name or telephone number, we may be unable to contact you or process your request.

Submitting a form does not create a purchase agreement, reservation or other binding obligation.

6. Marketing Communications

We may send you information about available apartments, prices, special offers, project updates or similar property opportunities where:

• you have specifically agreed to receive such communications;
• you have requested relevant information; or
• marketing communication is otherwise permitted under applicable law.

You may opt out at any time by:

• replying to the communication;
• asking our manager to stop contacting you;
• contacting us at AFSAGENCY@GMAIL.COM.

Once you opt out, we will stop using your personal data for direct marketing. We may retain limited information necessary to record and respect your request.

Under Albanian data protection law, individuals have the right to object to the use of their data for direct marketing at any time.

7. Cookies and Similar Technologies

The website may use cookies and similar technologies to ensure proper functionality, remember preferences, improve performance and understand how visitors interact with the website.

Cookies may include:

Strictly necessary cookies

These cookies are required for the website to function correctly, maintain security and process form submissions.

Preference cookies

These cookies remember settings such as language preferences.

Analytics cookies

Where enabled and accepted, analytics cookies help us understand website traffic, page performance and visitor interactions.

Marketing cookies

Where enabled and accepted, marketing cookies may be used to measure advertising performance or display relevant advertising.

Non-essential cookies should only be activated after you provide consent through the cookie banner, where such consent is required.

You can manage cookies through the cookie settings available on the website or through your browser settings. Blocking certain cookies may affect website functionality.

Only keep the analytics and marketing sections above if these tools are actually installed on the website.

8. WhatsApp and External Communication Services

The website may include links that allow you to contact us through WhatsApp.

When you click a WhatsApp link, you leave our website and interact with a third-party service. WhatsApp may process your telephone number, profile information, message content, device information and other data in accordance with its own terms and privacy policy.

We are responsible for how we use the information you send to us, but we are not responsible for the independent processing activities of WhatsApp or other external platforms.

9. Sharing of Personal Data

We do not sell or rent your personal data.

We may share personal data only where necessary with:

• authorised employees and sales representatives;
• website hosting and maintenance providers;
• customer relationship management and communication service providers;
• email, telephone and messaging service providers;
• analytics or advertising providers, where applicable and permitted;
• lawyers, notaries, accountants and professional advisers;
• property registration or administrative authorities;
• public authorities where disclosure is required by law;
• service providers involved in completing a reservation or property transaction;
• potential successors in the event of a lawful business transfer, restructuring or sale.

Service providers may process personal data only for the relevant service and must apply appropriate confidentiality and security safeguards.

10. International Data Transfers

Some website, hosting, analytics, communication or cloud service providers may process personal data outside Albania or outside the country where you are located.

Where personal data are transferred internationally, we will take reasonable steps to ensure that an appropriate level of protection is provided. Depending on the destination and service provider, safeguards may include:

• an adequacy decision;
• standard contractual clauses;
• contractual data protection obligations;
• other safeguards permitted by applicable law.

The Albanian Information and Data Protection Commissioner supervises international transfers of personal data under the national legal framework.

11. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected.

As a general rule:

• unanswered or unsuccessful property enquiries may be retained for up to 24 months after the last communication;
• viewing and consultation records may be retained for up to 24 months after the last meaningful interaction;
• marketing information may be retained until you withdraw consent or object to marketing;
• reservation and purchase records may be retained for the duration of the transaction and for any additional period required by property, accounting, tax or other applicable laws;
• technical and security logs may be retained for a limited period necessary to maintain website security;
• cookie information is retained according to the duration stated in the cookie settings or cookie banner.

We may retain information for longer where necessary to comply with a legal obligation, resolve a dispute or establish, exercise or defend a legal claim.

12. Data Security

We use reasonable technical and organisational measures designed to protect personal data against:

• unauthorised access;
• accidental loss;
• misuse;
• alteration;
• disclosure;
• destruction.

These measures may include access restrictions, secure hosting, password protection, software updates, encrypted connections and internal confidentiality requirements.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure. Visitors should avoid sending confidential documents or sensitive information through ordinary website forms unless requested through a secure channel.

13. Your Data Protection Rights

Subject to applicable law and any legal limitations, you may have the right to:

• receive information about how your personal data are processed;
• request access to your personal data;
• request correction of inaccurate or incomplete information;
• request deletion of your personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• object to direct marketing at any time;
• receive certain data in a structured and machine-readable format;
• request the transfer of eligible data to another controller;
• withdraw consent at any time;
• request information about recipients of your data;
• avoid decisions based solely on automated processing where they produce legal or similarly significant effects;
• lodge a complaint with the competent supervisory authority.

Requests should be sent to AFSAGENCY@GMAIL.COM. We may ask you to provide information necessary to confirm your identity before responding.

Under Albania’s Law No. 124/2024, requests concerning access, correction and erasure should generally be handled no later than 30 days after receipt, subject to applicable conditions and exceptions.

14. Automated Decision-Making

We do not currently use personal data to make decisions based solely on automated processing that produce legal or similarly significant effects.

If this changes, we will update this Privacy Policy and provide the information required by applicable law.

15. Children’s Privacy

The website and the apartments marketed through it are not directed at children.

We do not knowingly collect personal data directly from individuals under the applicable age of legal consent. If you believe that a child has provided personal information through the website, please contact us so that we can review and, where appropriate, delete the information.

16. Third-Party Websites

The website may contain links to external websites, maps, social media platforms or communication services.

External services operate under their own privacy policies. We are not responsible for the content, security or privacy practices of third-party websites and recommend reviewing their privacy information before providing personal data.

17. Complaints

Please contact us first if you have a concern about how we process your personal data. We will make reasonable efforts to review and resolve your request.

You also have the right to submit a complaint to:

Commissioner for the Right to Information and Protection of Personal Data

Address: Rr. “Abdi Toptani”, Nd. 5, Postal Code 1001, Tirana, Albania
Email: info@idp.al
Telephone: +355 4 223 7200

The Commissioner is Albania’s independent supervisory authority for personal data protection and accepts complaints from individuals who believe that their personal data have been processed unlawfully.

18. Changes to This Privacy Policy

We may update this Privacy Policy where necessary to reflect:

• changes to the website;
• new services or technologies;
• changes in our processing activities;
• legal or regulatory requirements.

The updated version will be published on this page with a revised “Last updated” date.

Material changes may also be communicated through the website or another appropriate method.

19. Contact Us

For questions, requests or concerns regarding personal data, contact:

AFS Agency / Garden Hill Residence
Email: AFSAGENCY@GMAIL.COM
Phone / WhatsApp: +355 68 449 9944
Address: [insert registered business address]