Privacy Notice Condo App

  1. Definitions and Interpretation

In this Notice, the following terms shall have the following meanings:

Account

Means an account required to access and/or use certain areas and features of CondoApp.

Personal Data

Means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via CondoApp. This definition shall, where applicable, incorporate the definitions provided in the Ley 8968 “Protección de la Persona frente al tratamiento de sus datos personales” (hereinafter “Law 8968”) on Costa Rica’s Law on Data Protection.

 

We/Us/Our

Means Doral Overseas Corporation S.A., a company registered in Costa Rica under company number 3-101-536816, whose registered address is Costa Rica, San José, Montes de Oca, San Pedro, Barrio Dent, Edificio Omala segundo piso.

  1. Information about Us

2.1 CondoApp is owned and operated by Doral Overseas Corporation S.A.

2.2 For any questions on how your data is handled please contact info@condoapp.info .

  1. What does this policy cover?

This Privacy Notice applies only to your use of CondoApp. CondoApp may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

  1. Your Rights

4.1 As a data subject, you have the following rights under the Law 8968, which this Notice and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 10);
4.1.3 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 10);
4.1.4 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided herein and We will do Our best to solve the problem for you.

  1. What Data do We collect?

Depending upon your use of CondoApp, We may collect some or all of the following personal and non-personal data:

5.1 name;
5.2 date of birth;
5.3 gender;
5.4 business/company name; 
5.5 job title;
5.6 profession;
5.7 contact information such as email addresses and telephone numbers;
5.8 demographic information such as home or work addresses;
5.9 financial information such as credit / debit card numbers;
5.10 IP address;
5.11 operating system.

5.12 App usage and how you interact with the services

  1. How do We use your data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under Law 8968 at all times.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to CondoApp;
6.2.3 Personalising and tailoring your experience on CondoApp;
6.2.4 Supplying Our services to you of facilitating the tenancy process;
6.2.5 Personalising and tailoring Our services for you;
6.2.6 Replying to emails from you;
6.2.7 Market research; and
6.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
6.2.9 Sharing your personal data with Bamago Realtors Group S.A.

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone with information, news and offers on Our products and/or services as well as products and/or services of Bamago Realtors Group S.A.

6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.5 We do not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected. Data will only be retained for different periods in accordance with applicable laws (for example, tax purposes).

  1. How and where do We store your data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2 Technical Data Security Measures:

7.2.1 All emails containing Personal Data must be encrypted;

7.2.2 All emails containing Personal Data must be marked ‘confidential’;

7.2.3 Personal Data may only be transmitted over secure networks;

7.2.4 Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;

7.2.5 Personal Data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;

7.2.6 Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;

7.2.7 Where Personal Data is to be transferred in hardcopy form, it should be passed directly to the recipient in accordance with this Policy;

7.2.8 All Personal Data transferred physically should be transferred in a suitable container marked “confidential”;

7.2.9 No Personal Data may be shared informally;

7.2.10 All hardcopies of Personal Data, along with any electronic copies stored on physical media should be stored securely;

7.2.11 No Personal Data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;

7.2.12 Personal Data must be handled with care at all times and should not be left unattended or on view;

7.2.13 Computers used to view Personal Data must always be locked before being left unattended;

7.2.14 No Personal Data should be stored on any mobile device, whether such device belongs to the Company or otherwise unless required by applicable law

7.2.15 No Personal Data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy;

7.2.16 All Personal Data stored electronically should be backed up regularly with backups stored onsite. All backups should be encrypted;

7.2.17 All electronic copies of Personal Data should be stored securely using passwords and encryption;

7.2.18 All passwords used to protect Personal Data should be changed regularly and should must be secure;

7.2.19 Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

7.2.20 All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;

7.2.21 No software may be installed on any Company-owned computer or device without approval; and

7.3 Organisational Data Security Measures:

7.3.1 The following organisational measures are in place within the Company to protect the security of personal data:

7.3.2 All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Law 8968and under the Company’s Privacy Policy;

7.3.3 Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;

7.3.4 All employees and other parties working on behalf of the Company handling Personal Data will be appropriately trained to do so;

7.3.5 All employees and other parties working on behalf of the Company handling Personal Data will be appropriately supervised;

7.3.6 All employees and other parties working on behalf of the Company handling Personal Data should exercise care and caution when discussing any work relating to Personal Data at all times;

7.3.7 Methods of collecting, holding, and processing Personal Data shall be regularly evaluated and reviewed;

7.3.8 The performance of those employees and other parties working on behalf of the Company handling Personal Data shall be regularly evaluated and reviewed;

7.3.9 All employees and other parties working on behalf of the Company handling Personal Data will be bound by contract to comply with the Law 8968and the Company’s Privacy Policy;

7.3.10 All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the Law 8968and the Company’s Privacy Policy;

7.3.11 Where any agent, contractor or other party working on behalf of the Company handling Personal Data fails in their obligations under the Law 8968and the Company’s Privacy Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

  1. Do We share your data?

8.1 In order to provide our integrated services to you, We may be required to share your data with the third parties listed in 6.3 of this Notice.

8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

8.3 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.4 We may compile statistics about the use of CondoApp including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of applicable law.

  1. What happens if Our business changes hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

  1. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@condoapp.info  {or by telephone on (506)8497-5757}.

Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

  1. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted and you will be deemed to have accepted the terms of the Privacy Policy on your first use of CondoApp following the alterations. We recommend that you check this page regularly to keep up-to-date.