Privacy Policy
1. Purpose of this Notice
1.1 Dream Properties Ltd. ("Dream Properties" or "the Company") is committed to responsibly handling the information we collect from you and others while conducting our real estate business in the Cayman Islands.
1.2 This Privacy Notice outlines how Dream Properties may collect, use, and share information about you and individuals associated with you. It covers:
The types of information, including personal data, that we may collect;
How we may use and share the information we collect;
The legal grounds for using personal data;
The measures we have in place to protect and securely store the information we collect;
How long we retain the information we collect;
Your rights and choices regarding the information we hold;
How to contact us;
Complaints procedures; and
Changes to this Privacy Notice.
1.3 If you are a Dream Properties tenant or employee/officer, separate privacy notices will apply.
1.4 When we use "we," "our," or "us," we mean Dream Properties.
1.5 In the event of any conflict between the terms of this Privacy Notice and any other document related to data protection, this Privacy Notice takes precedence. However, its contents are not contractual.
1.6 An "individual connected to you" could include a guarantor, a company director, officer or employee, partners or members of a partnership, substantial owners, controlling persons, or beneficial owners, trustees, settlers or protectors of a trust, designated account holders, designated payment recipients, your attorney or representative (such as authorized signatories), agent, nominee, or any other persons or entities relevant to your relationship with us. Whenever we use "you," "individuals connected to you" should be considered included.
1.7 For the purposes of this Privacy Notice, Dream Properties will act as a data controller in accordance with the Cayman Islands Data Protection Law (as amended from time to time) (the "Law").
1.8 Please ensure that any relevant individuals are aware of this Privacy Notice and the individual rights and information it contains before providing their information to us or allowing us to obtain their information from another source. If you, or anyone on your behalf, provide information about an individual connected to you, you or they must first ensure that you or they have the authority and legal basis to do so.
2. Information We Collect:
2.1 Our Privacy Notice pertains to the personal data we collect about you. Personal data refers to any information that can directly or indirectly identify you as an individual (for example, if multiple pieces of information are combined). Data that is entirely anonymized or de-personalized will not be considered personal data.
2.2 Some of the personal data we hold about you may have been provided by you directly. Other personal data may have come from your solicitors, brokers, or other intermediaries, or from other sources that you have authorized us to obtain information from. We may also obtain personal data from publicly available sources.
2.3 We typically collect personal data such as:
a. Personal details (e.g., name, previous names, gender, date and place of birth, occupation)
b. Identification materials we may need to comply with our regulatory 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.)
c. Contact details (e.g., address, email address, position in the company, landline and mobile numbers)
d. Other information about you that you may have provided us 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
e. Financial information and information about your relationship with us, including your ways of interacting with us, sort code, and account numbers
f. Complaints or disputes you may have had with us and details of the underlying transaction (where applicable)
g. Information about you that is a matter of public record or readily obtainable and which we deem relevant (media, court judgments, etc.)
h. Sales and marketing information (e.g., offers you have received from us and how you reacted to them)
i. Records of correspondence and other communications between you and your representatives and us, including email, telephone calls, letters, and the like
j. 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)
k. Information from third-party providers who assist us to combat fraud, money laundering, and other crimes.
2.4 In addition to the above, in relation to our website, www.dreamproperties.ky, we may also collect:
a. 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.
b. 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.
c. 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.
d. 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.
2.5 Please note that the website is not designed or intended for children, and we do not knowingly collect data relating to children.
2.6 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.
3: Use of Personal Data
At all times, we will only use your personal data in accordance with the law. The following are the most common circumstances under which we will use your personal data:
a. To fulfill our contractual obligations with you.
b. To comply with legal or regulatory requirements.
c. When it is necessary for our legitimate interests, or the legitimate interests of a third party, and your interests and fundamental rights do not override those interests.
d. To protect your interests, or the interests of someone else.
e. When it is needed for public interest or official purposes, such as complying with a court order or regulatory directive.
Based on these reasons for using your data, we typically use your information for the following purposes:
4. To permit selected third parties:
To contact you in relation to a contract we have with you.
4.1 IP Addresses
We may gather information about your computer (or mobile device), such as your IP address, operating system, and browser type, for system administration or commercial purposes. This data represents statistical information about how our users browse the site and their actions, and does not reveal any personal identity.
4.2 Cookies
To enhance your experience when using this site and improve the site itself, we utilize cookies and similar technologies to distinguish you from other users. Our Cookie Policy, available at www.dreamproperties.ky/cookies, provides a detailed account of the cookies we employ and the purposes they serve.
5.Sharing your Personal Data
5.1 We may share your personal data with other parties where it is lawful to do so, for the following reasons:
a. To comply with our contractual obligations or your instructions;
b. To fulfill a public or legal duty (such as detecting and preventing fraud, tax evasion, or complying with a court order);
c. In connection with regulatory reporting, litigation, or to assert or defend legal rights and interests;
d. When we have a legitimate business reason to do so (such as managing risk or verifying identity);
e. With your consent, when we have asked for it;
5.2 Parties we might share your personal data with include (but are not limited to):
a. Service providers who provide IT and system administration services, anti-money laundering service providers, and services that enable us to perform our contract with you;
b. Property developers who process your personal data to arrange and facilitate your visit to their marketing suite;
c. Advertisers and advertising networks (including social media) that require data to select and serve relevant ads to you.
d. Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accountancy services.
e. Banks you instruct us to make payments to and receive payments from;
f. Third parties who host the Website or provide services related to it, including IT security providers;
g. Parties involved in potential or actual corporate restructuring, merger, acquisition, or takeover, including any transfer of our rights or duties under our agreement with you;
h. Law enforcement, government, courts, dispute resolution bodies, our regulators, auditors, and any party appointed or requested by our regulators to carry out investigations or audits of our activities;
i. Parties involved in disputes, including disputed transactions;
j. Fraud prevention agencies who use personal data to detect and prevent fraud and other financial crimes, and to verify your identity;
k. Parties who provide instructions to us on your behalf (such as under a Power of Attorney, solicitors, intermediaries, investment managers, etc.);
l. Anybody else you instruct us to share your information with;
m. Insurers who may provide cover for your investment with us;
5.3 We may share aggregated and/or anonymized or de-personalized data with third parties for analytics, marketing, and research purposes. In such cases, we will ensure that neither you nor any other person will be identifiable from the data.
6. Retention of personal data
6.1 We only retain personal data for as long as necessary for the purpose for which it was collected or as required by applicable laws and regulations. Our records are typically kept for at least six (6) years after the end of our contractual relationship with you, or longer depending on the type of data and relevant regulations.
6.2 We may retain personal data for longer periods where we have a legitimate interest to do so, such as to address complaints, defend our rights in litigation or other dispute resolution processes, or to comply with requests from regulators or judicial authorities.
6.3 Any information that is no longer required to be held and has no purpose for us to keep will be promptly deleted, destroyed or returned to you.
6.4 If we share your personal data with third parties, their privacy notices, as well as applicable laws and regulations, will determine how long they need to retain your data
7. international transfers of personal data
7.1 In cases where we need to transfer your personal data outside of the Cayman Islands, we will ensure that the transfer is conducted lawfully and that appropriate measures are taken to protect the security of the data. This may include putting separate legal agreements in place with the recipient of the data.
7.2 There are several reasons why we may need to transfer your personal data outside of the Cayman Islands, including:
a. To fulfill our contractual obligations to you;
b. To comply with legal obligations;
c. To protect the public interest; or
d. To serve your or our legitimate interests.
7.3 In certain countries, the law may require us to share specific information with authorities, such as tax authorities. We will only share information with parties who have lawful authority to access it and only to the extent that such parties are permitted to see it.
8. Individuals’ rights
8.1 As an individual or "data subject", you possess certain rights with regards to your personal data. These rights include:
a. The right to access information we hold about you and to receive information on how we process it;
b. The right to object to and withdraw your consent to our processing of your data. You can exercise this right at any time. Nevertheless, we may continue to process your personal data if there is another legal obligation or legitimate reason to do so. Please note that depending on the kind of processing you object to, we may no longer be able to fulfill our contractual obligations with you.
c. The right to request the rectification of any inaccurate or incomplete information we hold about you;
d. In some circumstances, you have the right to request the erasure and deletion of personal data we hold. However, we may still be entitled or required by law to retain it.
e. The right to object to and request that we restrict our processing of your information in some circumstances. Please note that despite this general right, we may be entitled under the law to continue processing the information and/or refuse that request.
8.2 You also have the right to file a complaint with the data protection regulator in the Cayman Islands, which is the Office of the Ombudsman. You can access their website here: ombudsman.ky
8.3 You may also seek redress for any violation of your data protection rights in the Cayman Islands courts or challenge a decision by the regulator.
9. Miscellaneous
9.1 It is important that you provide us with accurate, complete, and up-to-date personal information, and inform us of any changes as soon as possible. This ensures that we are able to fulfill our obligations to you and maintain the accuracy of your personal information.
9.2 We take the security and confidentiality of your personal information seriously and use various measures, such as encryption and other security protocols, to ensure that it is protected. Our employees and any third parties who may handle your information on our behalf are required to comply with applicable data protection laws and regulations and adhere to our internal compliance standards. If you require further information on our data protection measures, please do not hesitate to contact us using the contact details provided below.
9.3 This Privacy Notice is governed by the laws of the Cayman Islands. In the event of any disputes arising from or in connection with this Privacy Notice, the exclusive jurisdiction of the Cayman Islands courts shall apply.
10. Contact us
For any further questions or queries in relation to this Privacy Notice, please email [email protected] or call us on 1-345-62- DREAM.
1.1 Dream Properties Ltd. ("Dream Properties" or "the Company") is committed to responsibly handling the information we collect from you and others while conducting our real estate business in the Cayman Islands.
1.2 This Privacy Notice outlines how Dream Properties may collect, use, and share information about you and individuals associated with you. It covers:
The types of information, including personal data, that we may collect;
How we may use and share the information we collect;
The legal grounds for using personal data;
The measures we have in place to protect and securely store the information we collect;
How long we retain the information we collect;
Your rights and choices regarding the information we hold;
How to contact us;
Complaints procedures; and
Changes to this Privacy Notice.
1.3 If you are a Dream Properties tenant or employee/officer, separate privacy notices will apply.
1.4 When we use "we," "our," or "us," we mean Dream Properties.
1.5 In the event of any conflict between the terms of this Privacy Notice and any other document related to data protection, this Privacy Notice takes precedence. However, its contents are not contractual.
1.6 An "individual connected to you" could include a guarantor, a company director, officer or employee, partners or members of a partnership, substantial owners, controlling persons, or beneficial owners, trustees, settlers or protectors of a trust, designated account holders, designated payment recipients, your attorney or representative (such as authorized signatories), agent, nominee, or any other persons or entities relevant to your relationship with us. Whenever we use "you," "individuals connected to you" should be considered included.
1.7 For the purposes of this Privacy Notice, Dream Properties will act as a data controller in accordance with the Cayman Islands Data Protection Law (as amended from time to time) (the "Law").
1.8 Please ensure that any relevant individuals are aware of this Privacy Notice and the individual rights and information it contains before providing their information to us or allowing us to obtain their information from another source. If you, or anyone on your behalf, provide information about an individual connected to you, you or they must first ensure that you or they have the authority and legal basis to do so.
2. Information We Collect:
2.1 Our Privacy Notice pertains to the personal data we collect about you. Personal data refers to any information that can directly or indirectly identify you as an individual (for example, if multiple pieces of information are combined). Data that is entirely anonymized or de-personalized will not be considered personal data.
2.2 Some of the personal data we hold about you may have been provided by you directly. Other personal data may have come from your solicitors, brokers, or other intermediaries, or from other sources that you have authorized us to obtain information from. We may also obtain personal data from publicly available sources.
2.3 We typically collect personal data such as:
a. Personal details (e.g., name, previous names, gender, date and place of birth, occupation)
b. Identification materials we may need to comply with our regulatory 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.)
c. Contact details (e.g., address, email address, position in the company, landline and mobile numbers)
d. Other information about you that you may have provided us 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
e. Financial information and information about your relationship with us, including your ways of interacting with us, sort code, and account numbers
f. Complaints or disputes you may have had with us and details of the underlying transaction (where applicable)
g. Information about you that is a matter of public record or readily obtainable and which we deem relevant (media, court judgments, etc.)
h. Sales and marketing information (e.g., offers you have received from us and how you reacted to them)
i. Records of correspondence and other communications between you and your representatives and us, including email, telephone calls, letters, and the like
j. 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)
k. Information from third-party providers who assist us to combat fraud, money laundering, and other crimes.
2.4 In addition to the above, in relation to our website, www.dreamproperties.ky, we may also collect:
a. 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.
b. 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.
c. 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.
d. 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.
2.5 Please note that the website is not designed or intended for children, and we do not knowingly collect data relating to children.
2.6 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.
3: Use of Personal Data
At all times, we will only use your personal data in accordance with the law. The following are the most common circumstances under which we will use your personal data:
a. To fulfill our contractual obligations with you.
b. To comply with legal or regulatory requirements.
c. When it is necessary for our legitimate interests, or the legitimate interests of a third party, and your interests and fundamental rights do not override those interests.
d. To protect your interests, or the interests of someone else.
e. When it is needed for public interest or official purposes, such as complying with a court order or regulatory directive.
Based on these reasons for using your data, we typically use your information for the following purposes:
4. To permit selected third parties:
To contact you in relation to a contract we have with you.
- To fulfill our contractual obligations with you, and to provide you with the information, products, and services you have requested from us.
- To provide you with information about other goods and services we offer that we believe may interest you.
- We may allow selected third parties to provide you with information about goods or services that may interest you, and to assist us in improving and optimizing our advertising, marketing materials, content, services, and website. This will be done with your consent or based on our legitimate interests.
- We may use your personal data to assist us in improving and optimizing our advertising, marketing materials, content, services, and website. This will be done based on our legitimate interests.
- We may use your personal data to notify you of any changes to our service, which is necessary to perform our contract with you, comply with legal obligations, and/or based on our legitimate interests.
- We may use your personal data to ensure that the content from our website is presented in the most effective way for you and your computer, based on our legitimate interests.
- We may use your personal data to verify your identity, which is necessary to comply with legal obligations and/or based on our legitimate interests.
- We may use your personal data as part of our efforts to keep our website safe and secure, and to prevent or detect fraud. This is necessary to comply with legal obligations and/or based on our legitimate interests.
- We may use your personal data to provide customer support, which is necessary to perform our contract with you.
- To enable you to participate in property viewings, open house events, or visits to property marketing suites, and to fulfill our contractual obligations with you (performance of a contract; legitimate interests; compliance with legal obligations).
- To fulfill our legal obligations and comply with any requirements imposed by law or court order (legal obligations).
- If you have viewed a property through us and we have been dis-instructed, we may disclose your name to the landlord or vendor to avoid potential commission disputes, which is necessary for our legitimate interests (legitimate interests).
4.1 IP Addresses
We may gather information about your computer (or mobile device), such as your IP address, operating system, and browser type, for system administration or commercial purposes. This data represents statistical information about how our users browse the site and their actions, and does not reveal any personal identity.
4.2 Cookies
To enhance your experience when using this site and improve the site itself, we utilize cookies and similar technologies to distinguish you from other users. Our Cookie Policy, available at www.dreamproperties.ky/cookies, provides a detailed account of the cookies we employ and the purposes they serve.
5.Sharing your Personal Data
5.1 We may share your personal data with other parties where it is lawful to do so, for the following reasons:
a. To comply with our contractual obligations or your instructions;
b. To fulfill a public or legal duty (such as detecting and preventing fraud, tax evasion, or complying with a court order);
c. In connection with regulatory reporting, litigation, or to assert or defend legal rights and interests;
d. When we have a legitimate business reason to do so (such as managing risk or verifying identity);
e. With your consent, when we have asked for it;
5.2 Parties we might share your personal data with include (but are not limited to):
a. Service providers who provide IT and system administration services, anti-money laundering service providers, and services that enable us to perform our contract with you;
b. Property developers who process your personal data to arrange and facilitate your visit to their marketing suite;
c. Advertisers and advertising networks (including social media) that require data to select and serve relevant ads to you.
d. Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accountancy services.
e. Banks you instruct us to make payments to and receive payments from;
f. Third parties who host the Website or provide services related to it, including IT security providers;
g. Parties involved in potential or actual corporate restructuring, merger, acquisition, or takeover, including any transfer of our rights or duties under our agreement with you;
h. Law enforcement, government, courts, dispute resolution bodies, our regulators, auditors, and any party appointed or requested by our regulators to carry out investigations or audits of our activities;
i. Parties involved in disputes, including disputed transactions;
j. Fraud prevention agencies who use personal data to detect and prevent fraud and other financial crimes, and to verify your identity;
k. Parties who provide instructions to us on your behalf (such as under a Power of Attorney, solicitors, intermediaries, investment managers, etc.);
l. Anybody else you instruct us to share your information with;
m. Insurers who may provide cover for your investment with us;
5.3 We may share aggregated and/or anonymized or de-personalized data with third parties for analytics, marketing, and research purposes. In such cases, we will ensure that neither you nor any other person will be identifiable from the data.
6. Retention of personal data
6.1 We only retain personal data for as long as necessary for the purpose for which it was collected or as required by applicable laws and regulations. Our records are typically kept for at least six (6) years after the end of our contractual relationship with you, or longer depending on the type of data and relevant regulations.
6.2 We may retain personal data for longer periods where we have a legitimate interest to do so, such as to address complaints, defend our rights in litigation or other dispute resolution processes, or to comply with requests from regulators or judicial authorities.
6.3 Any information that is no longer required to be held and has no purpose for us to keep will be promptly deleted, destroyed or returned to you.
6.4 If we share your personal data with third parties, their privacy notices, as well as applicable laws and regulations, will determine how long they need to retain your data
7. international transfers of personal data
7.1 In cases where we need to transfer your personal data outside of the Cayman Islands, we will ensure that the transfer is conducted lawfully and that appropriate measures are taken to protect the security of the data. This may include putting separate legal agreements in place with the recipient of the data.
7.2 There are several reasons why we may need to transfer your personal data outside of the Cayman Islands, including:
a. To fulfill our contractual obligations to you;
b. To comply with legal obligations;
c. To protect the public interest; or
d. To serve your or our legitimate interests.
7.3 In certain countries, the law may require us to share specific information with authorities, such as tax authorities. We will only share information with parties who have lawful authority to access it and only to the extent that such parties are permitted to see it.
8. Individuals’ rights
8.1 As an individual or "data subject", you possess certain rights with regards to your personal data. These rights include:
a. The right to access information we hold about you and to receive information on how we process it;
b. The right to object to and withdraw your consent to our processing of your data. You can exercise this right at any time. Nevertheless, we may continue to process your personal data if there is another legal obligation or legitimate reason to do so. Please note that depending on the kind of processing you object to, we may no longer be able to fulfill our contractual obligations with you.
c. The right to request the rectification of any inaccurate or incomplete information we hold about you;
d. In some circumstances, you have the right to request the erasure and deletion of personal data we hold. However, we may still be entitled or required by law to retain it.
e. The right to object to and request that we restrict our processing of your information in some circumstances. Please note that despite this general right, we may be entitled under the law to continue processing the information and/or refuse that request.
8.2 You also have the right to file a complaint with the data protection regulator in the Cayman Islands, which is the Office of the Ombudsman. You can access their website here: ombudsman.ky
8.3 You may also seek redress for any violation of your data protection rights in the Cayman Islands courts or challenge a decision by the regulator.
9. Miscellaneous
9.1 It is important that you provide us with accurate, complete, and up-to-date personal information, and inform us of any changes as soon as possible. This ensures that we are able to fulfill our obligations to you and maintain the accuracy of your personal information.
9.2 We take the security and confidentiality of your personal information seriously and use various measures, such as encryption and other security protocols, to ensure that it is protected. Our employees and any third parties who may handle your information on our behalf are required to comply with applicable data protection laws and regulations and adhere to our internal compliance standards. If you require further information on our data protection measures, please do not hesitate to contact us using the contact details provided below.
9.3 This Privacy Notice is governed by the laws of the Cayman Islands. In the event of any disputes arising from or in connection with this Privacy Notice, the exclusive jurisdiction of the Cayman Islands courts shall apply.
10. Contact us
For any further questions or queries in relation to this Privacy Notice, please email [email protected] or call us on 1-345-62- DREAM.