Privacy Notice
Cayman Islands Sotheby’s International Realty
This privacy notice applies to the processing of all personal information carried out by or on behalf of Cayman Islands Sotheby’s International Realty, The company referred to in this notice as “CISIR” and references to “we”, “us” or “our” are references to Cayman Islands Sotheby’s International Realty.
The purpose of this Privacy Notice is to explain to our customers, supplies and other counterparties (“you”) how we collect and use your personal information in connection with our business. “Personal information” means information relating to a living individual who can be identified (directly or indirectly) from that information.
We respect individual’s rights to privacy and the protection of personal information. We endeavour to adhere to and comply with applicable data protection laws, including the Cayman Islands Data Protection Law, 2019.
The information we collect
CISIR is a data controller of personal information that we process in connection with our business. We regularly collect and processes personal information provided by or in respect of our customers, suppliers and other counterparties.
Some of the personal data we hold about you will have been supplied by yourself. Other personal data may have come from your solicitors, broker or other intermediary, or other sources you’ve asked us to obtain information from. We might also get some personal data from publicly available sources.
Some of the personal data we collect may include any or all of the following:
- personal details (e.g. name, previous names, gender, date and place of birth, occupation);
- identification materials we may need for our compliance obligations (e.g. a copy of your passport or national identity card, national insurance number, utility bills, financial details and/or source of wealth etc.);
- contact details (e.g. address, email address, position in company, landline and mobile numbers);
- other information about you which you may have provided us with during the course of our relationship with you, e.g. by filling out forms or during face-to-face contact, telephone, email and the like;
- financial information and information about your relationship with us, including your ways of interacting with us, sort code and account numbers;
- complaints or disputes you may have had with us and details of the underlying transaction (where applicable);
- information about you which is a matter of public record or readily obtainable and which we deem relevant (media, court judgements etc.);
- sales and marketing information (e.g. offers you have received from us and how you reacted to them);
- records of correspondence and other communications between you and your representatives and us, including email, telephone calls, letters and the like;
- information that we need to support our regulatory obligations (e.g. information about transaction details, detection of any suspicious and unusual activity and information about parties connected to you or these activities); and information from third-party providers who assist us to combat fraud, money laundering and other crimes.
In addition to the above, in relation to our Website we may also collect:
- information that you provide to us, such as when you fill out a contact or web form, or if you register to receive alerts or updates;
- information that we obtain or learn, such as information about the browser or device you use to access the Website, how you use this site and the pages you visit, traffic and location data;
- information you provide to us if you experience problems when using the Website. We may also ask you to complete surveys for research purposes, although you don’t have to respond to these; and
- if we have an existing relationship with you, and we are able to identify you from information obtained or provided by your use of the site, we may associate those sets of information, for example to enable us to respond to a query you have submitted.
Please note that the Website is not designed or intended for children and we do not knowingly collect data relating to children.
We may also collect certain types of sensitive or special category data about you, such as details about any criminal records or information about your health, political affiliations, ethnicity or religious beliefs.
Purposes of processing your information
We collect, handle, process, store and use your personal information for the following purposes:
- providing the information and services that you have requested;
- entering into or completing a contract or transaction with you;
- managing and maintaining our relationship with you, including for ongoing customer service;
- communicating with you about our products and services, including sending you notifications, and updates and otherwise marketing to you (unless you ask us not to do this);
- confirming your identity or age to the extent required or appropriate;
- administering, conducting, monitoring and analysing our business, including to enhance and support our operations and service levels, monitor sales data and analyse risks;
- complying with applicable laws, regulations, court orders, codes of practice, guidelines or similar requirements or requests applicable to us.
Unless you have told us that you do not want to hear from us, we may send you marketing information (including details of our products or services which we believe may be of interest to you), by mail, telephone, email, text and other forms of electronic communication.
How we hold and share your information
We take all reasonable steps to safeguard the physical and electronic security of personal information that we hold, and require that service providers to whom we transfer personal information also take such steps.
Your information may be shared with and processed by other CISIR affiliates for the purposes set out above.
Cookies
Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the websites, pages visited, language preferences, and other anonymous traffic data. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Service.
Strictly necessary cookies are essential, as they enable you to move around the Service and use its features. Without these cookies we could not, for example, authenticate your login or remember that you are logged-in as you move through the Service.
Analytics & performances cookies collect information about how the Service is used, for example which pages users visit most often and if any error messages are displayed on certain pages. Information collected using these cookies is used to monitor activity on the Service and understand how it is being used.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org.
Where we have your consent;
- where required to perform the relationship we have with you, for example providing an email with requested information directly to you;
- where required for compliance with applicable law or regulation or a court order or similar requirement;
- with third parties providing services to us, such as IT service providers, auditors, professional advisors and other agents and sub-contractors acting on our behalf;
- in anonymised form as part of statistics or other aggregated data shared with third parties; or
- where it is otherwise permitted by law or necessary for our legitimate interests or those of a third party and not inconsistent with the purposes listed above.
We may transfer your personal information to organisations outside of the Cayman Islands, including to countries where data protection laws may be less stringent than they are in the Cayman Islands.
Individuals’ Rights
As an individual or “data subject”, you have certain rights in relation to your personal data. These rights include:
- the right to access information we hold about you and to obtain information about how we process it;
- the right to object to and withdraw your consent to our processing of your data. This right can be exercised at any time. However, we may continue to process your personal data if there is another legitimate reason or legal obligation for doing so. Please also note that depending on which kind of processing you object to, we may no longer be able to perform our contractual obligations with you.
- the right to request that we rectify information we hold about you if it is inaccurate or incomplete;
- in some circumstances, you have the right to request that erasure and deletion of personal data we hold. We may however continue to retain it if we are entitled or required by law to do so;
- the right to object to, and to request that we restrict, our processing of your information in some circumstances. Please note that despite this general right we may be entitled under law to continue processing the information and / or to refuse that request.
If you wish to exercise any of these rights, or if you have any queries or complaints about how we use your personal information please contact us at 345.623.1234 or by email at connect@sothebysrealty.ky.
You also have the right to complain to the data protection regulator in the Cayman Islands, which is the Office of the Ombudsman. You can access their website at www.ombudsman.ky
You may also be able to seek redress for any violation of your data protection rights in the Cayman Islands courts or challenge a decision by the regulator.
We may update our Privacy Notice from time to time. When we do, we will publish the updated Privacy Notice on our website.
