01. INTRODUCTION

This Privacy Policy explains our personal data practices and the options available to individuals as it relates to the way in which they wish their personal data to be used.

Oriental Developers (Caribbean) ltd. and its subsidiary, Anichi Development (“us”, “our” or “we”) respects your privacy, and is committed to protecting the privacy, confidentiality and security of the personal data you provide to us or that we collect about you when you use our website, social media pages we control, software applications available on computers and mobile devices that include a link to this Privacy Policy as well as when you provide your information on the telephone to our office, or in person through interactions with our personnel and our respective partners – all collectively referred to herein as the Sites.  Please be aware that our privacy practices may vary depending on the country within which we operate to reflect the prevailing laws of the land. Nevertheless, where possible, we commit to protecting and securing your personal data and complying with the abiding privacy and data protection laws.

You may be asked to consent to the terms of this Privacy Policy when browsing our website, interacting with our advertisements, consulting with our personnel, or otherwise corresponding with us via all sites, and the law – if required. Continued use of the Sites will constitute your deemed consent to the terms of this Privacy Policy.

02. PERSONAL INFORMATION WE COLLECT

Personal Information You Provide

When using our Sites, you may voluntarily provide certain information about yourself or others, such as when you subscribe to our mailing list, request a brochure, or complete our reservation, subscription, sales and purchase agreements. We may collect Personal Information (information that identifies you or relates to you as an identifiable person) that you may provide through the Sites about yourself or others such as:

• Name, date and place of birth, passport and visa information;
• Postal address;
• Telephone number;
• Email address;
• Medical records;
• Police Records;
• Credit or debit card number, expiration date and security code;
• Social media account information;
• Company/business name and address;
• Business account number;
• Personal and family demographic information (age, gender, country and preferred language);
• IP address;
• Preferences for receiving communications from us or for surveys or promotional offers.

Automatically Collected Information

Our website collects statistical information about users to ensure better user experience and website functioning. For this purpose, we may track your movement within the website, the pages from which you were referred, access times and browser types. We only use this information in aggregate and do not link it to you personally. To gauge the effectiveness of our website and analyze site traffic, understand customer needs and trends, we do collect some generic information about our visitors. Our web servers recognize and automatically log a visitor’s domain name, the web page from which a visitor enters our websites, which pages a visitor visits and for how long, and the visitor’s IP address. We may use anonymous tracking technologies to collect, store and sometimes track information for statistical purposes and to improve the services we provide, including using it to evaluate and improve our website. We also collect and store information automatically using cookies and similar technology as described below.

This information does not constitute Personal Information. If we combine anonymized or aggregated data with Personal Information, we will treat the combined information as Personal Information according to this Privacy Notice.

03. HOW WE USE YOUR INFORMATION

We may use Personal Information you submit and non-Personal Information we automatically collect for the purposes identified in this Privacy Policy for our business use and the legal bases, including, for example:

• Marketing of our solutions;
• Completing and filing reservation, subscription, sales and purchase agreements;
• Completing, assessing, and submitting citizenship applications;
• Soliciting invoices for services rendered;
• Producing quotations for citizenship sales;
• Confirming meetings and site visits;
• Conducting statistical or demographic analysis;
• Tracking performance of electronic communications;
• Sending you emails that relate to a resort stay;
• Sending you communications, such as construction updates or promotional offers and benefits;
• Communicating special offers, competitions, newsletters, and featured items if you choose to receive such notices;
• Responding to your inquiries, complaints and other communications.

04. DISCLOSING YOUR INFORMATION

As a player in the global Citizenship by Investment Industry, we will be required from time to time to share information across geographical boundaries as a means of better refining our offering, customer experience, marketing and sales efforts, and providing you with optimal service on a consistent basis. As such, your personal information may be shared as reasonably necessary and as set out in this Privacy Policy as follows to:

• Any partner with which Oriental has an abiding agreement;
• Any marketing offices operated by Oriental;
• Promoter, sales agent, personal assistant, employer or spouse that has supplied us with your Personal Information;
• Third parties which we have received your consent;
• Trusted third partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures including;
• Our marketing and advertising partners to provide you with more-relevant ads on our website and to encourage you to return to our website and to ActiveCampaign, who securely host emails and act as a supplier to distribute our email communications. We contractually require these service providers to keep your Personal Information safe and secure and they are only permitted to use your Personal Information for the purposes we specify.
• To third parties not affiliated with Oriental if we have a good-faith belief that it is reasonably necessary to: (1) meet any applicable law, regulation, legal process or enforceable governmental request; (2) enforce applicable terms of service, including investigation of potential violations; (3) detect, prevent, or otherwise address illegality, fraud, security or technical issues; and (4) protect against harm to the rights, property or safety of Oriental, our users or the public as required or permitted by law; and (5) to any third parties to the extent necessary with respect to a sale of all or part of our business operations or assets and/or resorts that are no longer managed or owned by Oriental.

05. OVERSEAS DATA TRANSFERS

By using and/or purchasing our goods and services, we may transfer your Personal Information across multiple jurisdictions. Thus, we may transfer and store your Personal Information:

• On our website and on our virtual private server facilitated by Media Temple;
• In Roseau, Dominica where our corporate head office is located or;
• To those countries where we have marketing offices;
• To countries where our trusted third-party providers or advisors are located.

Some of these countries may not offer the same level of privacy protection but we will take all reasonable steps to ensure such transfers are taken with adequate security to maintain your privacy.

06. EXPLAINING THE LEGAL BASES FOR PROCESSING

The legal bases for collecting and processing your Personal Information includes:

• Consent – we collect and process your data with your consent e.g. when you tick a box to receive marketing communication.
• Legal compliance – if required by applicable law, e.g. police, fraud investigations or court orders, we may need to collect and process your data.
• Legitimate interest – to pursue our legitimate interests such as providing services and products you have requested in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

07. SECURITY

We use reasonable technical, administrative and physical measures to protect Personal Information contained in our system against misuse, loss or alteration. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that you use to send e-mails and submit Personal Information to us over the Internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you use will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of your Personal Information before we receive it.

08. WITHDRAWING YOUR CONSENT

You do not have to provide us with your Personal Information. However, if you choose not to provide certain Personal Information we request and/or require consent use, you will still be able to visit our Sites but you may be unable to access certain options, products or services and we may not, as a result, be able to fulfil your real estate purchase and citizenship processing.

We offer you the choice of how you receive communications from us. All marketing communications we send to you will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive marketing you may opt-out of receiving these communications by clicking on the opt-out section of the marketing communication or changing your account settings, this will remove you from our marketing lists. You have the right to tell us to stop using your information for our direct marketing purposes. Please send your written request, including your name and contact information to the address listed below in How To Contact Us. We will honor your request within 30 days of receiving it or sooner if required by applicable law. Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding enquiries made to us, and that we may hold your details so we do not send you marketing communications in the future.

09. THIRD PARTY LINKS

We may permit third parties to link to our Sites or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. We do not assume responsibility or liability of any nature whatsoever for the activities conducted or information contained in the third-party websites.

10. CHILDREN'S PRIVACY

We do not knowingly collect Personal Information from children under the age of 13, though we may collect Personal Information about a child as part of the citizenship application process or to participate in activities on the website but always with the consent of a parent or guardian.

11. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Whenever we collect or process your Personal Information, we will only keep it for as long as is necessary for the purpose for which it was collected, active legal proceedings, an identifiable and ongoing legal business need and to the extent permissible by applicable law.

Where we cannot justify the retention of the information, such Personal Information will be safely and securely deleted, disposed of, blocked and/or anonymised for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

12. CHANGES TO THIS PRIVACY POLICY

From time to time and without notice we may make changes to this Privacy Policy. From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change at some time in the future, we will post the Privacy Policy changes to our Sites to notify you of these changes and provide you with the ability to opt out of these new uses. Any revised Privacy Policy will only apply prospectively to Personal Information or non-Personal Information collected or modified after the effective date of the revised policy.

13. HOW TO CONTACT US

You may exercise any of your principal rights expressed in the European Union General Data Protection Regulation in relation to your Personal Information, or if you have any questions or complaints regarding this Privacy Policy, or privacy concerns, by contacting our head office by email at info@anichidevelopment.com; or by post to Oriental Developers (Caribbean) Ltd., Dorset House, 14 Hanover Street, Roseau, Commonwealth of Dominica, 00109, Attn: Legal Privacy.

In order to ensure your request is dealt with expeditiously, please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any Personal Information regarding you, or in case we need to contact you to obtain any additional information, we may require to make that determination.

You may also direct your complaint/concern to the applicable data protection authority.

14. COOKIES POLICY

We use cookies to improve your experience on our websites and to recommend content that may be of interest to you. You can find out more below about what cookies are, the cookies we use and how to switch them off.

You can indicate your acceptance to our use of cookies in accordance with this policy by clicking OK in the appropriate place on the banner that appears on the website or continuing to use the Sites after the banner has been shown. However, please note that if you do not click “OK but continue to browse the websites, you will be deemed to have accepted our use of cookies (and what we use them for) in accordance with this Privacy Policy.

What are cookies?

A cookie is a text file containing small amounts of information which is downloaded to your device when you access a website. The text file is then sent back to our server each time your browser requests a page from the server. This enables us to operate the website more effectively and load the website so that it reflects your personal preferences, based on your previous browsing on the website, as well as keywords, we may be able to gather from URLs of other webpages from which you accessed the website.

What cookies do we use?

When you visit the websites, the following types of cookies may be downloaded to your device:

• Analytical and Performance Cookies
  We may use analytics service providers for website traffic analysis and reporting. Analytics service providers generate statistical and other information about the use of the website by using cookies. They allow us to recognise and count the number of visitors and to see how often visitors return to the website, how long they stay and how visitors move around our website when they are using it. This helps us to improve user experience of our website. The information generated relating to the website may be used to create reports about the use of the website and the analytics service provider will store this information.
• Advertising and Targeting Cookies
  These cookies record your visit to the website, the pages you have visited and the links you have followed to other websites. We will use this information to try and make our website and other sites that you visit more relevant to your interests. We may also share this information with others, such as other Oriental marketing offices, or promoters, for this purpose. We work with technology partners to support our website and to provide you with relevant information about the products and services of websites and on affiliated sites or sites within the advertising networks we work with. We may use cookies on our website to help us place relevant advertising on third-party websites when you visit those sites. If you disapprove of us doing this, please see the section of this policy titled “How do I turn cookies off?” below.
• Functionality Cookies
  We may use functional cookies that allow us to remember choices you have made on the website in order to enhance your user experience and provide you with content more specific to your interests.
• Strictly Necessary Cookies
  These are cookies that are required for the administration and operation of our website. Some cookies that we use are necessary for our websites to function properly and to enable you to move around the websites and use its features.
• Third Party Cookies
  Because Oriental has a strong presence on various social networks, we try and make it as easy as possible to share content and to see what content is popular on those networks. We add buttons to allow people to easily share to those networks. When we include these social ‘plugins’, it gives those sites the flexibility to use their own cookies. They can’t read any cookies we set from our website, and we can’t read any cookies they set, but it lets them do the same kind of traffic measuring that we do on the rest of the websites, and it also lets them know whether you’re logged into their site. Other sites and services (including, for example, advertising networks, providers of external services like web traffic analysis services and content recommendation engines) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

How do I turn cookies off?

If you do not wish us to install cookies or you don’t agree with how we use these cookies, you can change the settings on your internet browser to reject them. For more information please consult the “Help” section of your browser or visit AboutCookies.org, All About Cookies.org or YourAdChoices. Please note that if you do set your browser to reject cookies, you may not be able to use all of the features on our website.