InvestBySea
Consultation

Privacy policy

Effective from 31 August 2026

1. Who processes your personal data

The controller of your personal data is Assetvia s. r. o., with its registered office at Sibírska 1608/4, 831 02 Bratislava – Nové Mesto, Slovakia, Reg. no.: 57839051, registered in the Commercial Register of the Bratislava III City Court, section Sro, insert no. 203155/B (hereinafter “Assetvia”, “InvestBySea”, “we” or “the controller”).

Contact for questions and for exercising your rights: info@investbysea.com.

InvestBySea is a trading name operated by Assetvia s. r. o.. No data protection officer under Article 37 of the GDPR has been appointed, because no such obligation arose for the controller.

2. Who and what this information applies to

This information applies to visitors to the InvestBySea website, and to people who send us an enquiry, request a free consultation, are interested in a particular property, or order the Individual property selection service, and to people who have been named to us as the source of a recommendation.

3. What data we process

  • contact details: name, e-mail address and telephone number, if you provide it;
  • enquiry data: country or location, budget, purpose of purchase, method of financing, preferred language of communication, preferred time of contact and method of contact, the selected listing, a link to the listing and the content of your message;
  • referral data: the name of the person who recommended InvestBySea to you, if you provide it; this is data about a third party, so please give it only where that person expects it. If we pay that person a referral reward, we also process the data needed to make the payment, in particular their name, surname and account number;
  • paid service data: selection criteria, a record of the order covering its date and agreed content, invoice details, payment status, the output delivered and communication about the service;
  • introduction data: the date and source of the enquiry, the matching of an interested party to a particular listing or partner, and the communication needed to deal with that interest;
  • technical data: IP address, device and browser type, request time and server security logs; and, for anonymous traffic analytics, the page visited, the referring page (referrer), UTM parameters and an anonymous record that a form was submitted successfully together with the type of enquiry. We do not store the IP address in the contact form database or in the Umami analytics database; it may appear temporarily in operational or security logs. Name, e-mail, telephone number and message content are not sent to Umami.

Please do not send us special categories of personal data, such as health data, unless it is necessary and agreed in advance.

4. Purposes and legal bases of processing

Enquiry, free consultation and pre-contractual communication. We process the data in order to answer your enquiry, arrange a consultation and take the steps you requested prior to entering into a contract. The legal basis is Article 6(1)(b) of the GDPR.

Individual property selection for €299. We process the data in order to receive and confirm the order, issue and record the invoice, provide the service, communicate with you and handle any complaint. The legal basis is Article 6(1)(b) of the GDPR; for accounting and tax documents, Article 6(1)(c) of the GDPR.

Passing your interest to our partner in Montenegro. If you ask for information about a particular listing, a viewing, contact with a local partner or the next steps in a purchase, we will pass the necessary data to that partner in order to take steps at your request under Article 6(1)(b) of the GDPR. We keep a record of the origin of the enquiry, the registration of the interested party and the entitlement to an introduction commission on the basis of our legitimate interest under Article 6(1)(f) of the GDPR. You have the right to object to processing based on legitimate interest.

Referral reward. If someone has given us your name as the source of a recommendation and an entitlement to a reward arises under the terms of use and provision of services, we process your data in order to assess the entitlement, pay the reward and keep accounting records. The legal basis is Article 6(1)(b) of the GDPR; for accounting and tax documents, Article 6(1)(c) of the GDPR. We inform a person named to us as the source of a recommendation about the processing of their data no later than our first contact with them.

Security and operation of the website. We process technical data in order to protect the website, prevent abuse, diagnose faults and resolve security incidents, on the basis of legitimate interest under Article 6(1)(f) of the GDPR.

Traffic analytics. To measure traffic, traffic sources and the performance of the website we use the self-hosted tool Umami, run as part of the website’s own hosting. Umami uses no cookies and stores no personally identifiable data. It records page views, the referrer, UTM parameters, device and browser type, and anonymous events such as a successful form submission and the type of enquiry. The content of a form, your name, e-mail and telephone number are not sent to analytics. We use this measurement on the basis of our legitimate interest under Article 6(1)(f) of the GDPR, in order to evaluate and improve the website and our marketing channels.

Protection of legal claims. We may retain and use the necessary data to establish, exercise or defend legal claims, on the basis of legitimate interest under Article 6(1)(f) of the GDPR.

We normally obtain personal data directly from you. Providing data in a form is voluntary; without the required contact details, however, we will not be able to deal with your enquiry or provide the service you ordered.

5. Who we disclose data to

The following may have access to the data to the extent necessary:

  • providers of hosting, e-mail, security and technical services, who process data for us under contract;
  • accounting, tax and legal advisers;
  • public authorities, where disclosure is required of us by law;
  • “CMM” d.o.o. Budva, Jadranski put bb, Budva, Montenegro, registration number 50511453, tax identification number 02742187 (hereinafter “CMM”), where its involvement is needed to deal with your interest in a property in Montenegro.

CMM acts as a separate controller when dealing with your interest further. We may pass to it, in particular, your name, e-mail, telephone number, the selected listing, budget, criteria and the content of the communication needed to make contact, arrange a viewing or take the next steps. CMM is responsible for its subsequent processing of the data and for providing its own personal data information.

6. Transfer of data to Montenegro

Montenegro is not covered by a European Commission adequacy decision on the protection of personal data. We therefore transfer data to CMM on the basis of the European Commission’s standard contractual clauses under Commission Implementing Decision (EU) 2021/914, module 1 – transfer between two controllers, in accordance with Article 46(2)(c) of the GDPR. The clauses are signed by Assetvia and CMM and are supplemented by an assessment of the conditions of the transfer and by appropriate technical and organisational measures.

On request we will provide you with a copy of the standard contractual clauses used, or with information about the safeguards applied; trade secrets and other protected information may be redacted as appropriate. Send your request to info@investbysea.com.

7. How long we keep data

  • an ordinary enquiry or a request for a free consultation: 12 months from the last communication, where the interest does not develop further;
  • an enquiry passed to CMM and the record of the interested party’s registration: for the duration of active communication and no more than 3 years from the last communication, unless longer retention is needed for a legal claim;
  • Individual property selection data: 3 years from full provision of the service or from the end of the contract; accounting and tax documents 10 years, unless a legal regulation requires a different period;
  • ordinary technical and security logs: for as long as is needed to run and protect the website; in the event of a security incident, until it is resolved and until the period for bringing related claims has expired.

Once the relevant period has expired we delete or anonymise the data, unless its further retention is required by law or by the protection of legal claims.

8. Cookies

The website currently uses only the necessary NEXT_LOCALE cookie, to remember your language version for the duration of a session. For anonymous traffic analytics we use self-hosted Umami, which uses no cookies. We do not use Google Analytics, the Meta Pixel, or marketing cookies or advertising pixels. Details are set out on the Cookies page.

9. Your rights

Subject to the conditions laid down by the GDPR, you have the right:

  • to obtain confirmation of whether we process your data, and access to it;
  • to request rectification of inaccurate data or completion of incomplete data;
  • to request erasure or restriction of processing;
  • to receive your data in a portable format, where the processing is based on a contract and is carried out by automated means;
  • to object to processing based on legitimate interest;
  • to lodge a complaint with a supervisory authority.

You can exercise these rights at info@investbysea.com. Before dealing with a request we may verify your identity by appropriate means. We will reply within the period laid down by the GDPR.

10. Automated decision-making and security

We do not carry out automated individual decision-making or profiling that would produce legal effects concerning you or similarly significantly affect you. We use appropriate technical and organisational measures to protect data against unauthorised access, loss, alteration or disclosure.

11. Complaint to a supervisory authority

If you believe that we are processing your data contrary to the law, you may file a motion to commence proceedings with the Office for Personal Data Protection of the Slovak Republic, Galvaniho Business Centrum II, Galvaniho 7/B, 821 04 Bratislava, Slovak Republic, e-mail: statny.dozor@pdp.gov.sk, website: www.dataprotection.gov.sk.

12. Changes to this information

We may update this information as appropriate, in particular where the scope of our services, the technologies used, the recipients of data or the applicable law change. The current version and its effective date will always be published on this page.