COMMERCIAL CONSENT POLICY

1. Data Controller
   Promotora Caribbean Coast Corp.
   Project: Töa Club Náutico
   Address: Panama City, Republic of Panama
   Website: www.toaclubnautico.com
   
   Promotora Caribbean Coast Corp acts as the data controller for personal data used for commercial purposes and may rely on authorized data processors or technology providers who comply with principles of confidentiality, security, and data protection.

2. Purpose of Commercial Consent
   The commercial consent authorizes Töa Club Náutico to use the data subject’s personal information for the following purposes:

   • To send promotional and advertising information related to the project, its services, pre-sale phases, memberships, and special events.
   • To communicate news or updates about project development, member benefits, and exclusive activities.
   • To invite individuals to corporate events or personalized nautical experiences.
   • To conduct surveys or satisfaction studies to improve the services offered.
   • To maintain direct communication with interested parties or members through electronic channels (email, WhatsApp, SMS, social networks, or equivalent means).

   Under no circumstances will personal data be used for purposes other than those listed above or for communications not authorized by the data subject.

3. Legal Basis for Processing
   The processing of personal data for commercial purposes is based on the freely given, express, informed, and verifiable consent of the data subject, granted through:

   1. Electronic forms with acceptance checkboxes.
   2. Confirmations by email or digital messaging.
   3. Physical or digital signatures on registration forms or contracts.

   Consent may be revoked at any time by the data subject without retroactive effect.

4. Types of Commercial Communications
   Communications sent by Töa Club Náutico may include:

   1. Newsletters.
   2. Invitations to events, presentations, or nautical experiences.
   3. Pre-sale campaigns or exclusive member benefits.
   4. Offers of related or complementary products and services.
   5. Inspirational content connected to the nautical and Caribbean lifestyle promoted by the project.

   All communications will include a clear and visible mechanism for unsubscribing or withdrawing consent.

5. Data Subject Rights
   Data subjects may exercise the following rights at any time, in accordance with Law 81 of 2019:

   1. Access: To know what personal data Töa Club Náutico holds.
   2. Rectification: To correct inaccurate or outdated data.
   3. Erasure (Cancellation): To request deletion of their personal data.
   4. Objection: To refuse to receive further commercial communications.
   5. Portability: To request the transfer of their data to another controller.

   Requests must be submitted to: contacto@toaclubnautico.com. All requests will be handled within the timeframes and procedures established by applicable law.

6. Revocation of Consent
   The data subject may revoke their consent to receive commercial communications at any time through any of the following methods:

   • By clicking the “Unsubscribe” link included in each email.
   • By sending a request to contacto@toaclubnautico.com.
   • By making a direct request to an authorized representative of Töa Club Náutico.

   Revocation of consent will not affect the lawfulness of processing based on consent before its withdrawal.

7. Security and Confidentiality Measures
   Töa Club Náutico implements technical, organizational, and administrative measures to guarantee the confidentiality, integrity, and availability of the personal data it processes.
   It also ensures that all service providers and data processors adhere to international standards of information security and data confidentiality.
    
8. International Data Transfers
   If communications or the use of technological platforms involve the international transfer of personal data, Töa Club Náutico shall ensure that such transfers are carried out under mechanisms recognized by Law 81 of 2019, guaranteeing adequate levels of protection.
    
9. Policy Updates
   Töa Club Náutico may modify this Commercial Consent Policy at any time to reflect regulatory, technological, or internal management changes.
   Updates will be published on the official website www.toaclubnautico.com, indicating the date of the most recent revision.
    

10. Applicable Law and Jurisdiction
    This Policy is governed by the laws of the Republic of Panama, in particular:

    1. Law 81 of 2019 on Personal Data Protection
    2. Law 51 of 2008 on Electronic Commerce

    Any dispute shall be resolved before the competent courts of Panama City, Republic of Panama.***
     

11. Validity
    This Policy enters into force upon its official publication on Töa Club Náutico’s digital channels.

Promotora Caribbean Coast Corp. - Töa Club Náutico Project
Website: www.toaclubnautico.com