Privacy Policy
Last Updated: 5 September 2026
Egemen Erul ("Egemen Erul", "we", "us" or "our") respects the privacy of the people who visit the egemenerul.com website, use the contact form or the Digital Assistant, and get in touch about professional services.
This Privacy Policy explains which personal data may be collected, the purposes for which it may be used, whom it may be shared with, how long it may be retained, and the rights you may have in relation to your personal data.
Personal data is processed in line with the data-protection legislation in force in Northern Cyprus and, to the extent it applies, other relevant data-protection frameworks — guided by the principles of lawfulness, transparency, purpose limitation, data minimisation and security.
Data Controller
For personal-data processing activities carried out through this website, contact can be made through:
If applicable legislation additionally requires a registered business name, registration number or physical address for service to be disclosed, those details will be added to this page.
Information We May Collect
When you get in touch, only the information reasonably needed to understand, assess and respond to your request is collected.
This may include:
- first and last name;
- country;
- email address;
- phone or WhatsApp number;
- preferred contact method, time and language;
- the service you are interested in;
- the Northern Cyprus region or regions you are considering;
- property preferences;
- approximate budget range;
- travel or visit dates;
- accommodation, transport or concierge requests;
- company, project or business-development information;
- training needs, participant profile and organisation details;
- free text you enter into the Digital Assistant;
- messages you send through the contact form or other channels;
- the source of the enquiry, the page visited, the referring page and UTM campaign information;
- records of your privacy and marketing preferences.
Please do not submit passport, ID number, bank account, credit card, password or similar sensitive information through the website or Digital Assistant unless the service requires it.
The Digital Assistant
The Digital Assistant uses the information you provide to make sense of and structure your request.
For example, the system may:
- identify which service area your request relates to;
- use your earlier answers during the session so it does not ask for them again;
- structure your chosen region, date, budget or service preferences;
- suggest another service that is logically related to your request;
- prepare a short request summary before contact.
The Digital Assistant is not used, on its own, to make automated decisions that produce legal or similarly significant effects about you.
The summaries produced should be based only on the information you provide; the system should not infer sensitive personal characteristics you have not given.
How We Use Personal Information
Responding to Your Request
Assessing the request you submit through the contact form, the Digital Assistant, email or other channels, and getting in touch with you.
Structuring Your Service Request
Understanding your requests for real estate, international real estate marketing, business development, hospitality, Front Office & concierge and guest experience, Gaming Operations & Guest Relations, corporate training or Luxury concierge & VIP Service Coordination, and determining the appropriate scope.
Service Coordination
Where your request requires and it is appropriate, arranging communication and coordination with relevant independent or authorised service providers.
Business and Partnership Requests
Assessing business-development, project-marketing, collaboration or commercial-partnership requests.
Security and Abuse Prevention
Protecting the site, the forms and the Digital Assistant from spam, fraud, abuse or security threats.
Improving Site Performance
Where the necessary permissions have been given, assessing site usage through appropriate analytics and improving the user experience.
Marketing Communications
Contacting you about new content, services or professional updates only where you have given separate and optional consent.
You do not need to grant marketing consent to make a service request.
Legal Bases for Processing
Depending on the applicable law and the nature of the processing, personal data may be processed on one or more of the following bases:
- taking pre-contractual steps at your request;
- communicating with you and assessing your service request;
- fulfilling legal obligations;
- the legitimate interest of running the website and professional activities securely and effectively;
- valid consent for marketing and non-essential cookies;
- establishing, exercising or defending legal rights where necessary.
For processing based on consent, you may withdraw your consent at any time.
Sharing of Personal Information
Your personal information is not sold.
However, to the extent necessary to deliver the service, information may be shared with:
- web hosting and infrastructure providers;
- email and communications-service providers;
- database or CRM providers;
- information-technology and security-service providers;
- analytics-service providers, where permitted;
- independent professional specialists your request requires;
- hotel, transport, restaurant, villa, yacht, private aviation, event, security and other concierge service providers;
- authorised bodies and authorities where legally required.
Sharing is limited, as far as possible, to the information necessary for the relevant service.
Independent Third-Party Services
Some service requests may be coordinated through suitable independent or authorised service providers.
These may include, for example:
- hotel;
- transfer;
- chauffeured car;
- restaurant;
- villa;
- yacht;
- private jet;
- helicopter;
- event;
- security
requests. To the extent necessary to deliver these services, the relevant information may be shared with the service provider.
International Data Transfers
Where hosting, email, database, security, artificial-intelligence infrastructure or other technology services are delivered from different countries, personal data may be processed in another country.
Such transfers should be made with appropriate legal, contractual, technical and organisational safeguards to the extent required by applicable legislation.
Data Retention
Personal data is not retained for longer than necessary for the purpose for which it was collected.
When assessing the retention period, the following may be considered:
- the nature of the request or service;
- an ongoing professional relationship;
- legal obligations;
- possible dispute or claim periods;
- security requirements;
- deletion or objection requests
When the need for retention ends, data is securely deleted, destroyed or, where appropriate, anonymised.
Security
Reasonable technical and organisational measures are applied to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
Depending on the system, these may include:
- HTTPS;
- secure data transfer;
- server-side validation;
- access controls;
- administrator authentication;
- secure key and password management;
- spam and abuse controls;
- security logs
No internet transmission or storage method can be guaranteed to be completely secure.
Your Rights
Depending on the applicable data-protection legislation, you may have some of the following rights:
- access to your personal data;
- correction of inaccurate information;
- requesting deletion of data;
- requesting restriction of processing;
- objecting to certain processing;
- data portability, where applicable;
- withdrawing your consent;
- objecting to direct marketing;
- lodging a complaint with a competent data-protection authority.
You may send your requests to contact@egemenerul.com. Where necessary, reasonable identity verification may be requested.
Children's Privacy
The site and professional services are primarily intended for adult users and corporate clients. Personal data is not knowingly collected from children.
Third-Party Websites and Social Media
The site may contain links to LinkedIn, Instagram, Facebook, X and other independent websites. When you move to an external site, the privacy policy and terms of use of that third party apply.
Changes to This Policy
This policy may be updated due to legal, technical or operational changes. The current version and last-updated date are published on this page.