This Privacy and Data Protection Policy governs and establishes the necessary measures and procedures to guarantee the Right to Information Self-Determination of Users who share their personal data with the technological platform NATHY REALTY (hereinafter the Website) and generally with SunOnline LLC, headquartered at 30 N Gould St Ste R, Sheridan WY 82801, USA, email contact@nathyrealty.com (hereinafter NATHY REALTY or the CONTROLLER) and the social media profiles associated with the Website or the CONTROLLER.

INFORMED CONSENT

The data subjects (the ADVERTISER and the USER) GIVE THEIR FREE, SPECIFIC, EXPLICIT, INFORMED, AND UNEQUIVOCAL CONSENT to the CONTROLLER to process their personal data in accordance with this privacy policy, also validating this consent, acceptance, and understanding by any messaging means or electronic communication platform they use to contact NATHY REALTY, or by clicking on the acceptance box located in the registration forms provided by NATHY REALTY on each of the forms on its Website.

The refusal of the ADVERTISER or USER to GIVE THIS INFORMED CONSENT TO THE CONTROLLER restricts the possibility for the ADVERTISER or USER to acquire the services offered by NATHY REALTY, register on the NATHY REALTY platform, and contact NATHY REALTY through the digital communication channels provided by the latter, as well as on its social media.

Consequently, the acceptance of informed consent by the ADVERTISER and the USER includes express authorization for the CONTROLLER to process personal data in accordance with the following provisions:

1. DATA CONTROLLER

SunOnline LLC, headquartered at 30 N Gould St Ste R, Sheridan WY 82801, USA, email contact@nathyrealty.com, is hereinafter the CONTROLLER responsible for collecting, managing, processing, and deciding the purpose of the personal data provided to NATHY REALTY by the ADVERTISERS and USERS.

2. PERSONAL DATA SUBJECT TO PROCESSING

Personal data is understood as any data related to an identified or identifiable natural person. Therefore, to achieve the purpose established herein, the CONTROLLER will collect via the NATHY REALTY platform, web forms, and electronic messaging platforms, or on the NATHY REALTY social media profiles, the following personal data: full name, identification number, email address, phone number, profession, position, real address, IP address, geolocation, browser or mobile device metadata such as IMEI number, brand and model, and any other personal data necessary for the effective provision of the services offered by NATHY REALTY.

This Policy covers all personal data collected and processed by the CONTROLLER. The ADVERTISER and the USER commit to ensuring that the information provided during the registration process or at any other time is accurate, true, and truthful. If deemed necessary by NATHY REALTY, it may request any kind of additional documentation and personal information from the ADVERTISER or USER, which will be required by email or through the NATHY REALTY technological platform. Failure to present the requested documentation and/or information within seventy-two hours of sending the request may result in the suspension of access to the platform by NATHY REALTY.

3. PURPOSE OF PERSONAL DATA PROCESSING

When ADVERTISERS or USERS interact with the Soldvendido platform via the Website or any other service, product, or technology provided by NATHY REALTY, the purpose of collecting and processing personal data will be the registration, identification, and full and truthful authentication for access to the NATHY REALTY platform by the ADVERTISER or USER; conducting web analysis of the ADVERTISER and USER activity on the website to improve the user experience; browsing analysis of the ADVERTISER and USER on the CONTROLLER’s social media profiles, email sending; contact via social media; contact via messaging services; phone calls; advertising campaigns on search engines and social media; risk analysis, monitoring, and investigation of illicit activities in accordance with regulations related to money laundering and terrorist financing or lack of tax transparency; investigations, market segmentation to improve services and customer service decision-making and acquiring new users, among other legal and necessary purposes for the proper provision of services offered by NATHY REALTY and its business partners.

4. DURATION OF PERSONAL DATA RETENTION

The personal data of the USER and the ADVERTISER will be retained for a maximum period of 7 YEARS from the last date of activity of the ADVERTISER or USER with the NATHY REALTY platform. However, they will only be retained for the minimum time necessary for the purposes of processing specified in point (3), or until the ADVERTISER or USER requests their deletion, in which case only the data necessary for the exercise or defense of future claims and legal exceptions will be retained by the CONTROLLER.

5. RECIPIENT AND ACCESS TO PERSONAL DATA

The CONTROLLER is the final recipient of the personal data of the ADVERTISER and USER. The collaborators designated by the CONTROLLER for this purpose, as well as companies belonging to the same economic interest group as the CONTROLLER, will have access to these data. However, during the processing and realization of the purpose established in point 3 (three), the ADVERTISER and USER understand and accept that the CONTROLLER may share their personal data with a service provider, supplier, or technological intermediary or with companies of the same economic interest group as the CONTROLLER. The CONTROLLER commits to ensuring that these third parties or subcontractors comply with the minimum guarantees of Personal Data Protection established by international laws, specifically the legislation of the Republic of Panama and Costa Rica.

Similarly, the ADVERTISER and USER GIVE THEIR INFORMED CONSENT at this moment for the CONTROLLER to transfer their personal data in case of mergers, splits, acquisitions, or strategic alliances with third parties, understood as the necessary transfer of company assets to another, provided that this new corporate transformation involves the same processing purpose established in point 3 (three). In all the previous cases, the CONTROLLER will ensure that the new data controller complies with the same obligations to which NATHY REALTY is subject.

The ADVERTISER and USER understand that their personal data may be shared with authorities when necessary for legal investigations or other proceedings prescribed by law and in accordance with legitimate procedures established for this purpose in international regulations.

5.1. Third-Party Services

The CONTROLLER uses the following third-party services to achieve the objectives, which implies the processing by these third parties of certain data that may be considered personal data:

Google Services: This site uses cookies to implement Google features, such as Google Analytics and Google Ads, which allow analyzing how the User uses and navigates this website. To create a profile of the ADVERTISER and USER behavior to show them ads on Google LLC associated sites.

Company Information: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043.

See Google’s Privacy Policy

OVH: NATHY REALTY implements its general operation and the services it makes available to the User and the Advertiser through the tools and hosting services of this provider.

Company Information: OVH, Headquarters: 2 rue Kellermann – 59100 Roubaix – France.

See OVH’s Privacy Policy

MailJet: NATHY REALTY uses the services provided by this provider to implement the sending, tracking, and delivery of marketing and transactional emails.

Company Information: MailJet inc., 13-13 bis, rue de l’Aubrac Paris, 75012, France.

See MailJet’s Privacy Policy

5.3. Payment Services

The payment of all fees related to the services provided by the platform will be made through the payment gateway Stripe.com. The ADVERTISER and USER understand that this payment gateway may request personal information according to its own privacy policy to process the respective payments.

6. PRINCIPLES APPLIED TO DATA PROCESSING

The CONTROLLER commits through this Policy to collect, store, or use personal data for automated or manual processing, respecting the principles of data updating, minimization, veracity, integrity, and confidentiality, accuracy, transparency, and suitability for the purpose.

7. USER RIGHTS

In accordance with the General Data Protection Regulation of the European Union (GDPR), the California Consumer Privacy Act (CCPA), the Personal Data Protection Law of the Republic of Panama, and Law No. 8968, Protection of the Person Concerning the Processing of their Personal Data, the ADVERTISER and the USER have the following rights concerning the personal data collected and processed by the CONTROLLER:

7.1. Right to be Informed

The ADVERTISER and USER have the right to know how the data they provide to the CONTROLLER will be collected, processed, stored, and for what purposes, before providing it. This information is available in this Privacy and Data Protection Policy and in the General Terms of Use (Link to the Portal’s GTU).

7.2. Access to Information

Request the CONTROLLER to confirm or deny the existence of ADVERTISER and USER data in files or databases under the CONTROLLER’s control.

Inform about the use made of the ADVERTISER and USER’s personal data, its purpose, and the technical terms used for the data processing by the CONTROLLER.

7.3. Right to Rectification

The ADVERTISER and USER have the right to obtain rectification of their personal data and its update or deletion when it has been processed in violation of legal provisions, particularly due to its incomplete or inaccurate nature, or when it has been collected without the holder’s authorization.

7.4. Right of Revocation

The ADVERTISER and USER may revoke their informed consent for the processing of their personal data by the CONTROLLER, in which case only data necessary for the exercise or defense of future claims will be retained by the CONTROLLER.

7.5. Right of Deletion or Erasure

The ADVERTISER and USER may at any time request the CONTROLLER for the complete or partial deletion or erasure of the personal data of the holder, permanently, in which case only data necessary for the exercise or defense of future claims will be retained by the CONTROLLER. Exceptions to the erasure of personal data will be those established by law.

7.6. Right to Object

The ADVERTISER and USER may at any time request the CONTROLLER to stop transferring the personal data of the holder to third parties.

7.7. Right to Data Portability

The ADVERTISER and USER have the right to move, copy, or transfer their personal data from one controller to another, securely, in a readable and commonly used format.

To exercise any of these rights, the ADVERTISER and USER must send a written communication to the email address contact@nathyrealty.com, including a photocopy of their identification card or passport and any relevant information related to their request.

8. COOKIE POLICY

Cookies are any type of file created in the user’s browser to store and record data used on the user’s terminal equipment, to store information and retrieve already stored information. For more information on managing cookies, please read the NATHY REALTY Cookie Policy (Add link to Cookie Policy). This document and its acceptance are considered integral parts of this Privacy Policy.

9. SECRECY AND SECURITY OF PERSONAL DATA

The CONTROLLER undertakes to protect the personal data of the ADVERTISER and USER and to take all reasonable measures to do so. It also requires trusted third parties handling their personal data to have appropriate measures based on identified risks.

The CONTROLLER always does its utmost to protect your personal data and, once it has received your personal information, uses strict procedures and security features to try to prevent unauthorized access. Since sending information over the Internet is not completely secure, it cannot guarantee the security of data sent via the NATHY REALTY platform. Therefore, any information sent will be at the risk of the ADVERTISER and USER.

10. AMENDMENT OF PRIVACY AND PERSONAL DATA PROTECTION POLICY

The ADVERTISER and USER understand and accept that this Privacy and Personal Data Protection Policy may be revised and amended by NATHY REALTY at any time by publishing a new version on the Website or NATHY REALTY platform. Additionally, the ADVERTISER and USER understand that it is their obligation and responsibility to stay informed about news and events that NATHY REALTY publishes on its platform. It is understood that there is no obligation on the part of NATHY REALTY to individually notify the ADVERTISER or USER of changes made; these will be published on the NATHY REALTY platform.

The ADVERTISER and USER accept that they have read and understood this “PRIVACY AND PERSONAL DATA PROTECTION POLICY,” and by clicking on the checkbox and selecting “Accept,” as well as by using the NATHY REALTY platform, they expressly attest that they accept these provisions freely and consciously after reviewing information they find adequate and sufficient.

Last update: July 2024