Privacy Policy
1. About Us
REAL Academy is a trading name of N&T Real Learning & Development Ltd, a private limited liability company incorporated in the Republic of Cyprus, with registration number HE 491176, under the Companies Law, Cap. 113. Registered address: 29, Gerasimou Markora, Office 001, 1075, Nicosia, Cyprus.
N&T Real Learning & Development Ltd is the data controller responsible for your personal data. If you have any questions about how we handle your data, please contact us at info@real-academy.eu.
2. What This Policy Covers
This Privacy Policy explains what personal data we collect, why we collect it, how we use it, how long we retain it, and your rights in relation to it. It applies to all individuals who visit our website (real-academy.eu), enquire about or enrol in our programmes, or otherwise interact with REAL Academy.
3. What Personal Data We Collect
Depending on how you interact with us, we may collect the following categories of personal data:
A. Identity & contact data: full name, job title, employer or organisation, email address, phone number, and postal address.
B. Enrolment data: programme preferences, booking history, attendance records, and completion status.
C. Professional data: professional body membership (e.g. RICS affiliation), CPD records, and qualifications where voluntarily provided.
D. Communication data: records of email correspondence, enquiry forms, and any feedback submitted to us.
E. Technical data: IP address, browser type, and pages visited when you use our website, collected via cookies and analytics tools.
4. How We Collect Your Data
We collect personal data in the following ways: directly from you when you contact us by email, complete an enrolment form, or register for a programme; from your employer or organisation when they enrol you in a corporate or bespoke programme; and automatically through our website via cookies and analytics tools when you browse real-academy.eu.
5. Why We Process Your Data & Our Legal Basis
We process your personal data for the following purposes:
A. To manage your enrolment and deliver training programmes — this is necessary for the performance of a contract or to take steps at your request prior to entering a contract (Article 6(1)(b) GDPR).
B. To process invoices and manage payments — this is necessary for the performance of a contract and for compliance with our legal obligations (Article 6(1)(b) and 6(1)(c) GDPR).
To comply with ANAD/HRDA subsidy requirements. Where applicable, we are required to submit participant data to the Human Resource Development Authority of Cyprus as a condition of the subsidy scheme. This processing is necessary for compliance with a legal obligation (Article 6(1)(c) GDPR).
C. To issue CPD certificates and maintain professional development records — based on our legitimate interests in delivering a credible and compliant training service (Article 6(1)(f) GDPR).
D. To send you information about upcoming programmes and developments — based on your consent or our legitimate interests where you are an existing client or contact. You may opt out at any time by contacting us at info@real-academy.eu (Article 6(1)(a) and 6(1)(f) GDPR).
E. To improve our website and services — based on our legitimate interests in operating and developing our business (Article 6(1)(f) GDPR).
6. Sharing Your Data
We do not sell your personal data. We may share your data in the following circumstances:
Human Resource Development Authority of Cyprus (HRDA/ANAD): where your programme is subsidised under an ANAD scheme, we are required to submit participant data including attendance and completion records to the HRDA as part of the subsidy process.
Service providers: we may share data with trusted third-party providers who assist us in delivering our services, such as email platforms, document management tools, and website analytics providers. These providers process data on our behalf and are bound by appropriate data processing agreements.
Legal and regulatory obligations: we may disclose personal data where required to do so by law, court order, or regulatory authority.
We do not transfer your personal data outside the European Economic Area (EEA) unless appropriate safeguards are in place in accordance with GDPR requirements.
7. How Long We Retain Your Data
We retain personal data only for as long as necessary for the purposes for which it was collected, taking into account any legal, regulatory, or contractual obligations.
As a general guide: enrolment and attendance records are retained for a minimum of 5 years to satisfy ANAD audit requirements and general record-keeping obligations; invoicing and financial records are retained for 7 years in accordance with Cypriot tax and accounting law; CPD certificates and completion records are retained for a minimum of 5 years; marketing and communication data is retained until you opt out or withdraw consent; and website analytics data is retained in accordance with our cookie and analytics provider settings, typically no longer than 26 months.
8. Your Rights
Under GDPR, you have the following rights in relation to your personal data:
Right of access — you may request a copy of the personal data we hold about you.
Right to rectification — you may ask us to correct inaccurate or incomplete data.
Right to erasure — you may ask us to delete your data in certain circumstances, subject to our legal and contractual obligations.
Right to restriction — you may ask us to restrict the processing of your data in certain circumstances.
Right to data portability — you may request that we provide your data in a structured, commonly used format.
Right to object — you may object to processing based on legitimate interests, including direct marketing.
Right to withdraw consent — where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at info@real-academy.eu. We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the Commissioner for Personal Data Protection of the Republic of Cyprus at www.dataprotection.gov.cy.
9. Cookies
Our website uses cookies to understand how visitors use the site and to improve the user experience. Cookies are small text files placed on your device when you visit a website. We use analytics cookies (such as Google Analytics) to collect anonymised information about website usage. You may disable cookies through your browser settings, though this may affect your experience on the site. A full cookie notice is available on our website.
10. Data Security
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. These include restricted access to personal data, use of secure email and document storage, and regular review of our data handling practices. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected individuals in accordance with GDPR obligations.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The current version will always be published on real-academy.eu. We encourage you to review this policy periodically.
12. Contact & Complaints
REAL Academy (trading name of N&T Real Learning & Development Ltd) 29, Gerasimou Markora, Office 001, 1075, Nicosia, Cyprus | info@real-academy.eu | real-academy.eu
For data protection matters specifically, you may also contact the Commissioner for Personal Data Protection of the Republic of Cyprus: www.dataprotection.gov.cy
This Privacy Policy should be read alongside our Terms & Conditions and Refund & Cancellation Policy, all of which are available on our website.