My First Corner Co., Ltd. ("MFC," "My First Corner," "we," "us," or "our")

Last updated: 22/04/26

This Privacy Policy explains how MFC collects, uses, shares, and protects personal information in connection with our website, enquiry forms, messaging channels, and commercial real estate services. It applies to prospective and existing clients, website visitors, and anyone who contacts us through any of our published channels.

MFC is the data controller for the personal information described in this Policy.

1.  Information We Collect

We collect personal information in the following ways:

Information you give us directly. When you submit an enquiry form, email us, message us through WhatsApp, Telegram, Line, WeChat, or another platform, visit our office, or engage us as a client, we may collect:

• your name and preferred form of address;

• your email address, phone number, and preferred messaging channel;

• your country of residence and, where relevant, nationality;

• information about the type of property you are interested in (budget, location, asset class, timing, intended use);

• professional information you choose to share (occupation, company, investment experience);

• identification and compliance information where required to progress a transaction or satisfy anti-money-laundering obligations;

• any other information you choose to provide in the course of our communications.

Information collected automatically. When you visit our website, we and our service providers automatically collect:

• IP address, approximate geographic location (city/country level), device type, browser, operating system, referring URL, and pages viewed;

• cookie and similar-technology data (see our Cookie Notice);

• analytics data relating to how you interact with the site.

Information from third parties. We may receive information about you from developers, sellers, introducers, or other professional referrers who pass your enquiry to us with your consent, and from publicly available sources where relevant to verifying a transaction.

2. How We Use Your Information

We use personal information for the following purposes:

• to respond to enquiries and provide information about properties, developments, and market conditions;

• to provide brokerage services, including arranging viewings, introducing you to developers or sellers, and supporting transactions through to completion;

• to perform due diligence, market analysis, and other advisory work we have agreed to provide;

• to comply with legal, regulatory, and anti-money-laundering obligations;

• to administer our relationship with clients, including contracts, invoicing, and record-keeping;

• to send marketing communications about properties and market updates where you have opted in or where permitted by applicable law, with an option to unsubscribe at any time;

• to operate, maintain, secure, and improve our website;

• to protect our legal rights, prevent fraud, and investigate suspected misuse.

  
  

3. Legal Bases for Processing (EU / UK Visitors)

Where the EU General Data Protection Regulation (GDPR) or the UK GDPR applies, we rely on the following legal bases:

• Consent — for marketing emails, non-essential cookies, and certain messaging-platform communications. You may withdraw consent at any time.

• Contract — to take steps at your request before entering into a contract with you and to perform any contract we enter into.

• Legitimate interests — to respond to enquiries, operate and secure our website and business, analyse usage, and market our services to existing clients and enquirers in a manner they would reasonably expect. You may object to processing based on legitimate interests.

• Legal obligation — to comply with Cambodian law and, where applicable, laws of other jurisdictions (e.g. anti-money-laundering, tax, and record-keeping requirements).

  
  

4. How We Share Information

We do not sell personal information. We share information only as follows:

• Developers, sellers, and landlords — where you have asked us to progress an enquiry or negotiation in respect of a specific property, we share information necessary to do so.

• Professional advisers — lawyers, notaries, valuers, tax advisers, and similar professionals engaged in connection with a transaction, on your behalf or ours.

• Service providers — hosting, email, analytics, CRM, communications, and similar providers who process data on our instructions under appropriate confidentiality obligations.

• Regulators, authorities, and courts — where required by law, regulation, or legal process, or where necessary to protect our rights or those of others.

• Successors — in the event of a sale, merger, or reorganisation of MFC, personal information may be transferred as part of that transaction, subject to equivalent protection.

  
  

5. International Transfers

MFC is based in Cambodia. Some of our service providers (for example, email and cloud hosting) are located outside Cambodia, including in the United States, the European Union, and elsewhere in Asia.

Cambodia is not currently the subject of a European Commission or UK adequacy decision. Where we transfer personal data from the EU, UK, or other jurisdictions with transfer-restriction rules to a country without an equivalent decision, we use appropriate safeguards — typically Standard Contractual Clauses or equivalent — and apply technical and organisational measures designed to protect the data. You may contact us for further information about specific transfer arrangements.

6. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, which generally means:

• Enquiries that do not progress: up to 24 months from last contact, unless you ask us to delete the record sooner.

• Active clients: for the duration of our engagement plus the period required to deal with post-transaction matters.

• Completed transactions: for the period required by Cambodian tax, corporate, and anti-money-laundering law (typically ten years), and thereafter only where necessary for legal claims or compliance.

• Marketing lists: until you unsubscribe or ask to be removed.

  
  

7. Your Rights

Depending on where you live, you may have the following rights in respect of your personal information:

• Access — to a copy of the personal information we hold about you.

• Correction — of inaccurate or incomplete information.

• Deletion — of personal information in certain circumstances.

• Restriction or objection — to certain processing, including direct marketing.

• Portability — to receive certain information in a structured, machine-readable format.

• Withdrawal of consent — where processing is based on consent.

• Complaint — to a data protection authority in your country of residence.

Specific notice to California residents. Under the California Consumer Privacy Act (CCPA) as amended by the CPRA, California residents have rights to know, delete, correct, and limit the use of personal information, and a right not to be discriminated against for exercising those rights. MFC does not sell or share personal information for cross-context behavioural advertising as those terms are defined under California law.

To exercise any of these rights, please contact us through the channels on our website. We will respond within the period required by applicable law. We may need to verify your identity before acting on a request.

8. Security

We apply reasonable technical and organisational measures to protect personal information against unauthorised access, loss, and misuse. No system is perfectly secure, and we cannot guarantee absolute security of information transmitted to or from us. If you believe your interaction with us is no longer secure, please contact us immediately.

9. Children

Our services are not directed to children, and we do not knowingly collect personal information from individuals under the age of 18. If you believe a child has provided us with personal information, please contact us so we can delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The version published on our website is the version in force. Material changes will be brought to your attention where practical, including by notice on the website or, where appropriate, by direct communication.

11. Contact

Questions, requests, or complaints about this Privacy Policy or our handling of personal information should be directed to MFC through the contact channels on our website.