Privacy & Data Protection

01Who is responsible

The controller of your personal data is MFM Ventures Ltd, trading as Hypomo, registered in Malta under company number C 113871, with its registered office at Office 24, SOHO, The Strand, Triq l-Imsida, Gżira GZR 1401, Malta.

“Controller” means we decide what is collected and why, and we answer for it. For anything in this notice — a question, a request, a complaint — write to register@hypomo.com. A person reads that address. You will have an acknowledgement within five working days and a substantive answer within one month, which is the period the GDPR allows.

We are an estate agency operating under the Real Estate Agents, Property Brokers and Property Consultants Act (Chapter 615 of the Laws of Malta), and a subject person for the purposes of Malta's anti-money-laundering legislation. Both facts shape what we are obliged to collect and how long we must keep it.

02The short version

If you read nothing else:

• We collect what you tell us and — if you become a client — what the law obliges us to verify about you.
• We do not sell your data, rent it, or hand it to advertisers. There is no exception.
• The voice concierge sends your speech to Google for the length of the conversation. It is entirely optional. Please read §5 before you use it.
• You may see what we hold, correct it, take it elsewhere, or have it erased — subject only to records we are legally required to keep.
• If we handle you badly, the Information and Data Protection Commissioner in Malta will hear your complaint. We would rather you told us first.

03What we collect

Four kinds of information, gathered at different stages. Most visitors only ever reach the first.

Technical data — everyone who loads a page

Our host records ordinary server logs: your IP address, the time of the request, the page asked for, and your browser's user-agent string. This is the unavoidable exhaust of serving a website. We do not build a profile from it.

Inquiry data — if you write to us

Client data — if you retain us

A search generates a file: viewing itineraries, notes on preferences, offers made and received, correspondence with notaries and banks, and the documents a Maltese conveyance requires. Where you ask for an introduction to finance, that includes what the lender needs in order to assess you.

Due-diligence data — required by law, not by us

Before a transaction we must verify who you are and, where the rules require it, where the money comes from. That means identity documents, proof of address, and — depending on the transaction — evidence of source of funds or wealth, and screening against sanctions and politically-exposed-person lists. We collect this because we are obliged to, and we cannot proceed without it.

We do not seek special categories of data — health, beliefs, politics and the like. Where such information reaches us incidentally because it appears in a document you supply, we restrict it to what the file requires and use it for nothing else.

04Why, and on what basis

The GDPR requires a lawful basis for every use. Ours, purpose by purpose:

Where we rely on legitimate interests we have weighed ours against yours and concluded the processing is what you would reasonably expect. You may object — see §9 — and we will stop unless we have a compelling reason not to, which we would then explain to you.

05The voice concierge

The bell in the corner of this site opens a desk you can speak to. It is a real convenience and it is also the most invasive thing on this website, so it gets its own section.

What happens when you ring

• Your browser asks your permission for the microphone. Refuse, and nothing is captured; you may still type.
• While the line is open, your speech is streamed to Google's Gemini Live service and a spoken reply is streamed back. Google acts as our processor for this.
• A written transcript appears in the panel so you can see what was heard. It lives in your browser's memory only and is gone when you close the desk or the tab.
• The connection uses a single-use token minted by our server and valid for one session. Our own API key never reaches your browser.

What we keep

Nothing, unless you ask us to. We do not record the audio and we do not store the transcript on our servers. The one exception is deliberate and visible: if you ask the concierge to take your name so a colleague may telephone, it will read the details back to you for confirmation and then file them in our client register exactly as if you had typed them into the inquiry form. Nothing is filed without you offering it.

What it is not

The concierge is an automated assistant. It is instructed to speak only from a fixed set of facts about the house and to decline anything else, but no such system is perfect. It gives no legal, tax, financial or valuation advice; it cannot bind us to anything; and where accuracy matters you should rely on a person and, in due course, on the notary. If it tells you something that proves wrong, the written engagement and the deed govern — not the conversation.

If you would rather the feature did not exist for you, simply never ring the bell. It captures nothing until you do.

06Who else sees it

We do not sell, rent or trade personal data, and we disclose nothing to advertisers. Two groups do see it.

Our processors — acting on our instruction

Each is bound by a written agreement under Article 28 of the GDPR, may use the data only as we direct, and must keep it secure.

How your inquiry reaches us

An inquiry is delivered to the house by whichever routes are switched on — the client register, an email to the desk, or an internal notification service. If every one of them fails, the inquiry is written to our hosting provider's server log instead, so that a request for our help is never silently lost. Records written that way are retrieved and filed by hand, and the log entry ages out on the provider's ordinary retention cycle.

We would rather tell you that a copy may land in a server log than quietly let your message disappear because one system was down. If you would like that recovery record removed once we have filed your inquiry properly, ask us and we will do it.

Independent recipients — acting for themselves

A property transaction cannot be completed alone. These parties receive only what the step requires, and each is responsible for its own handling of it.

Advertising vendors — only if you allow them

If, and only if, you permit the Advertising category in the cookie card, Google, Meta and LinkedIn receive a signal that this browser visited us, so that our advertising can be shown to you elsewhere and its effect measured. For what they then do on their own platforms they act as controllers in their own right, or jointly with us, and their own notices govern it — we cannot vary them on your behalf.

Refuse the category and none of these vendors is contacted at all. Full detail, vendor by vendor and cookie by cookie, is in the Cookie Notice, §5.

What we will not do: we do not build advertising audiences from what you told a concierge, from your client file, or from any document supplied for due diligence. Advertising works from website behaviour and nothing else. We do not sell or share your details with data brokers, and we do not buy lists.

We will also disclose data where compelled — a court order, a regulator's lawful demand, or a reporting obligation under anti-money-laundering law. Where an AML disclosure is made we are generally forbidden by law from telling you, which is why §11 exists.

07Data leaving the EU

Some of our suppliers are established in the United States. Where personal data reaches them it leaves the European Economic Area, and we rely on the safeguards Chapter V of the GDPR requires:

• the EU–US Data Privacy Framework, where the supplier is certified under it; or
• the European Commission's Standard Contractual Clauses, together with an assessment of whether local law undermines them in practice, and additional measures — encryption in transit and at rest, minimisation — where it might.

The practical consequence is worth stating plainly: if you speak to the voice concierge, your voice travels to the United States. If that is unwelcome, write instead.

You may ask us for a copy of the transfer mechanism relied upon for any particular supplier, and we will provide it.

08How long we keep it

We keep data for as long as the purpose requires, then delete it. Where the law sets the period, the law wins.

When a period expires the data is deleted or irreversibly anonymised. Backups roll off on their own cycle, so a deletion may persist in backup for a short further period before it is overwritten.

09Your rights

These are yours by law, free to exercise, and using them will never affect how we treat you.

How to exercise them

Write to register@hypomo.com and say what you want. We may ask you to confirm your identity — we are not going to hand your file to someone who merely knows your name. We answer within one month, extendable by two further months for genuinely complex requests, in which case we will tell you why within the first month.

If we refuse any part of a request we will say so, explain the ground, and tell you how to challenge it.

10Cookies and measurement

Nothing that measures or advertises to you is set until you permit it. You are asked once, on arrival; refusing takes the same single click as accepting; and the site behaves identically whichever you choose.

Your choice is remembered for twelve months and may be changed or withdrawn at any moment from Cookie preferences in the footer of every page. Every cookie we are prepared to set is named, with its purpose and lifetime, in the Cookie Notice.

11Anti-money-laundering

As a subject person under the Prevention of Money Laundering Act and the regulations made under it, we are required to identify and verify our clients, to understand the source of funds in a transaction, to monitor the relationship, and to keep records of all of it.

Where we form a suspicion we are obliged to report it to the Financial Intelligence Analysis Unit. Maltese law generally prohibits us from telling you that a report has been made, or that one is being considered. This is not a discretion we exercise but a prohibition we obey, and we mention it so that the limit on our openness is itself open.

These obligations override your right to erasure for the records concerned, for the retention period set out in §8.

12Security

We take the measures Article 32 requires: encryption in transit across the whole site, access to the client register limited to those who need it and removed when they leave, credentials rotated when there is reason to, and hosting with suppliers who maintain recognised security certifications.

No system is impregnable and we will not pretend otherwise. If a breach occurs that is likely to risk your rights and freedoms, we will notify the Commissioner within 72 hours and tell you directly and in plain language — what happened, what it means for you, and what we are doing about it.

13Children

Our service is for adults transacting in property. We do not knowingly collect data from anyone under 16 and the site is not directed at children. Where a child's details appear in a family's file — because they will live in the house — we hold them only for that purpose. If you believe we hold a child's data without a proper basis, write to us and we will remove it.

14Automated decisions and profiling

We make no decisions about you by automated means alone, and we do not profile you in any way that produces legal effects or similarly significant consequences. You therefore have nothing to opt out of under Article 22.

The voice concierge is automated, but it decides nothing: it answers questions and, if asked, takes a message. Every judgement that affects you — which houses to show, what to advise, whether to act — is made by a person.

Where you have permitted advertising, the vendors in §6 place this browser into broad audiences — “visited the register”, “began an enquiry” — so that our advertising reaches people with some interest in Maltese property rather than everyone. That is profiling in the ordinary sense of the word and we would rather name it than not. It has no legal or similarly significant effect on you: it determines which advertisement you might see, and nothing about the service you receive, the houses you are shown, or the fee you pay. Refuse the category, or withdraw it later, and it does not happen at all.

15Complaints

Tell us first, if you are willing: register@hypomo.com. Most complaints are misunderstandings and most are settled in a day. Our full procedure is on the Complaints page.

You are entitled to go straight to the supervisory authority instead, and you need neither our permission nor our involvement:

Information and Data Protection Commissioner
Floor 2, Airways House, High Street, Sliema SLM 1549, Malta
idpc.org.mt · idpc.info@idpc.org.mt

If you are resident in another EEA state you may complain to your own national authority instead.

16Changes to this notice

When our practice changes, this page changes with it and the revision date at the top moves. Where a change materially affects your rights — a new purpose, a new category of recipient, a longer retention period — we will not rely on you noticing: we will tell those we hold contact details for, directly.

Previous versions are kept and available on request, so you can see what you were told at the time you told us anything.