Privacy Policy

1. Introduction

Your use of the Website is also subject to our Terms and Conditions.

For the purposes of the GDPR, the data controller is Inversiones Navetta SRL, located in Las Terrenas, Samana, Dominican Republic. You may contact us at info@navettaproperties.com regarding any data protection matters.

2. Information We Collect

We may collect the following categories of information depending on how you interact with us:

• Personal Information: Name, address, email address, phone number and identification documents (such as cedula or passport) provided during inquiries or transactions.
• Financial Information: Bank account details, payment information and transaction history collected when you engage in real estate transactions with us.
• Property Information: Details about properties you are buying, selling, renting, or listing through us, including address, value, condition and ownership documentation.
• Usage Information: IP address, browser type, device information, pages visited, time spent on pages and property search preferences collected automatically when you browse the Website.
• Communications: Records of your communications with us via email, phone, WhatsApp, contact forms, or other channels.

3. Legal Basis for Processing

Where the GDPR applies, we process your personal data on the following legal bases (Article 6 GDPR):

• Consent (Art. 6(1)(a)): When you subscribe to our newsletter, submit a contact form, or accept non-essential cookies. You may withdraw your consent at any time (see Section 9).
• Contract (Art. 6(1)(b)): When processing is necessary to perform or enter into a contract with you, such as facilitating a property sale, rental agreement, or property management service.
• Legal Obligation (Art. 6(1)(c)): When we are required by law to process your data, including anti-money laundering obligations under Dominican Republic Law No. 155-17 and tax reporting requirements.
• Legitimate Interest (Art. 6(1)(f)): When processing is necessary for our legitimate business interests, such as improving the Website, analyzing usage patterns, preventing fraud and ensuring security, provided these interests do not override your fundamental rights and freedoms.

4. How We Use Your Information

• Service Delivery: To provide requested services including property sales, rentals, management and related brokerage activities.
• Transaction Processing: To process payments, verify identities and complete real estate transactions.
• Communication: To respond to inquiries, provide property updates and send marketing communications. You may opt out of marketing emails at any time.
• Website Improvement: To analyze usage patterns, improve Website functionality and content and develop new features.
• Legal Compliance: To comply with applicable laws and regulations, including anti-money laundering requirements under Law No. 155-17, tax reporting obligations and court orders.
• Security: To protect against fraud, unauthorized access and other security threats.

5. Sharing Your Information

We do not sell your personal information. We may share your information with the following parties only as necessary:

• Service Providers: Trusted third-party providers who assist our operations and are bound by contractual confidentiality obligations and, where applicable, GDPR-compliant data processing agreements.
• Transaction Partners: Parties directly involved in a real estate transaction, including attorneys, notaries, banks, title companies and other brokers as necessary to facilitate the transaction.
• Legal Authorities: Government or regulatory bodies when required by law, court order, or to comply with anti-money laundering and other legal obligations.
• With Your Consent: Other parties when you have given us explicit consent to do so.

6. Named Data Processors and Third-Party Services

The following third-party services process data on our behalf in connection with the Website:

• Cloudflare, Inc. (USA) -- Content delivery, DNS, edge computing, web analytics (Cloudflare Zaraz) and security services. Privacy Policy
• Google LLC (USA) -- Google Analytics 4 (GA4) for website usage analytics, configured with anonymized IP collection. Privacy Policy
• Meta Platforms, Inc. (USA) -- Facebook Pixel for conversion tracking and audience measurement on the Website. Privacy Policy
• MailerLite UAB (Lithuania, EU) -- Newsletter subscription management and email marketing. Privacy Policy
• AlterEstate (Dominican Republic / USA / Mexico) -- Real estate CRM and property listing management platform. Privacy Policy
• DeepL SE (Germany, EU) -- Machine translation of website content. Privacy Policy

Each processor is contractually obligated to handle your data in accordance with this Privacy Policy and applicable data protection laws. We do not permit our processors to use your personal data for their own purposes.

7. Cookies and Consent

The Website uses cookies and similar tracking technologies. When you first visit the Website, a cookie consent banner is presented, allowing you to accept or decline non-essential cookies before they are placed on your device.

• Essential Cookies: Required for basic Website functionality such as navigation, language preferences and access to secure areas. These do not require consent.
• Analytics Cookies: Help us understand how visitors interact with the Website by collecting usage data. These are only loaded after you provide consent. Includes Google Analytics 4 (managed through Cloudflare Zaraz).
• Marketing Cookies: Used for conversion tracking and audience measurement. Includes the Facebook Pixel. These are only loaded after you provide consent.
• Functional Cookies: Remember your preferences such as language selection, saved property searches and favorites stored in your browser's localStorage.

You can change your cookie preferences at any time through the cookie settings accessible via the banner or by adjusting your browser settings. Withdrawing consent does not affect the lawfulness of processing based on consent given before withdrawal. Disabling certain cookies may affect Website functionality, including property search features and saved listings.

8. Data Security

We implement commercially reasonable technical and organizational measures to protect your information from unauthorized access, use, alteration, or disclosure. These measures include encrypted data transmission (SSL/TLS), secure server infrastructure, access controls and regular security assessments.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

9. Your Rights

Under Dominican Republic Law No. 172-13 and, where applicable, the GDPR, you have the following rights regarding your personal information:

• Access (GDPR Art. 15): Request a copy of the personal information we hold about you.
• Correction (GDPR Art. 16): Request correction of any inaccurate or incomplete personal information.
• Deletion (GDPR Art. 17): Request deletion of your personal information, subject to our legal retention obligations.
• Restriction (GDPR Art. 18): Request that we limit the processing of your personal information under certain circumstances.
• Objection (GDPR Art. 21): Object to the processing of your personal information for specific purposes, including direct marketing.
• Data Portability (GDPR Art. 20): Receive your personal information in a structured, commonly used and machine-readable format.
• Withdraw Consent (GDPR Art. 7(3)): Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. To withdraw consent for marketing emails, use the unsubscribe link in any email. To withdraw cookie consent, use the cookie settings on the Website. For all other withdrawals, contact us at the address below.
• Lodge a Complaint: If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. For EU/EEA residents, this is the Data Protection Authority in the EU/EEA member state of your habitual residence, place of work, or place of the alleged infringement. A list of EU Data Protection Authorities is available at edpb.europa.eu.

To exercise any of these rights, please contact us at info@navettaproperties.com. We will respond within 30 days, or within the timeframe required by applicable law.

10. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law:

• Transaction records: Retained for the period required by Dominican Republic tax and commercial law.
• Communication records: Retained for as long as necessary to address your inquiry or maintain the business relationship.
• Usage data and analytics: Retained in anonymized or aggregated form for Website improvement purposes.
• Marketing consent records: Retained for the duration of the consent and for a reasonable period afterward to demonstrate compliance.

11. International Data Transfers

The Company operates in the Dominican Republic and primarily stores data within this jurisdiction. Some of our third-party processors (listed in Section 6) are located in the United States and the European Union.

For transfers of personal data from the EU/EEA to countries outside the EU/EEA that have not been deemed to provide an adequate level of data protection by the European Commission (including the Dominican Republic and the United States), we rely on the following safeguards:

• Standard Contractual Clauses (SCCs): EU Commission-approved contractual clauses that provide appropriate data protection guarantees in data transfer agreements with our processors.
• EU-U.S. Data Privacy Framework: Where applicable, processors certified under the EU-U.S. Data Privacy Framework for transfers to the United States.
• Consent: In specific situations, your explicit consent to the transfer, given after being informed of the risks.

By using the Website, you acknowledge that your information may be transferred to and processed in these jurisdictions.

12. Children's Privacy

The Website and our services are not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete such information promptly.

13. Changes and General Provisions

Policy Updates: We may update this Privacy Policy from time to time. Changes become effective upon posting with an updated Effective Date. For material changes that affect your rights, we will make reasonable efforts to notify you (e.g., via email or a notice on the Website). Your continued use of the Website constitutes acceptance of the revised policy.

Governing Law: This Privacy Policy is governed by the laws of the Dominican Republic. For EU/EEA residents, nothing in this policy limits or excludes any rights you may have under the GDPR. Any disputes arising from this policy shall be resolved in the competent courts of the Dominican Republic, without prejudice to your right to lodge a complaint with your local EU Data Protection Authority.

Language: This Privacy Policy is drafted in English. In the event of any conflict with a translated version, the English version shall prevail.

Applicable Regulations: This Privacy Policy is designed to comply with Dominican Republic Law No. 172-13, the EU General Data Protection Regulation (GDPR) (EU) 2016/679, and other applicable data protection legislation. Where a conflict exists between local law and the GDPR, we will apply the standard that provides greater protection to the data subject.

14. Contact Information

For questions, concerns, or to exercise your data protection rights: