PRIVACY AND PERSONAL DATA PROTECTION POLICY
- Purpose and Scope
This Policy establishes the principles, rights, and procedures governing the collection, use, storage, processing, transfer, and protection of personal data obtained by Caribbean Coast Corp., promoter of the Töa Club Náutico project (hereinafter, “THE PROMOTER” or “Töa Club Náutico”), in accordance with Law 81 of 2019 on Personal Data Protection of the Republic of Panama.
This policy applies to all information collected through official websites, digital or physical forms, payment platforms, social networks, marketing automation tools, and any other communication channels authorized by Töa Club Náutico.
Data Controller Identification
- Data Controller: Promotora Caribbean Coast Corp.
- Project: Töa Club Náutico
- Address: Panama City, Republic of Panama
- Website: www.toaclubnautico.com
The promoter acts as the controller of personal data and, when applicable, may designate data processors in accordance with Article 28 of Law 81 of 2019.
- Definitions
In accordance with Law 81 of 2019, the following terms apply:- Personal data: Information relating to an identified or identifiable natural person.
- Data subject: The natural person to whom the data refers.
- Processing: Any operation performed on personal data (collection, storage, use, transfer, deletion, etc.).
- Controller: The entity that determines the purposes and means of the processing.
- Processor: The person or entity that processes data on behalf of the controller..
- Principles of Processing
The processing of personal data by Töa Club Náutico shall be governed by the following principles:- Lawfulness and transparency: Data shall be processed lawfully, fairly, and transparently.
- Legitimate purpose: Data shall be collected for specific, explicit, and legitimate purposes.
- Proportionality: Only data strictly necessary for the stated purpose shall be collected.
- Security: Appropriate technical and organizational measures shall be implemented.
- Accuracy: Data must be accurate and kept up to date.
- Confidentiality: The privacy and integrity of the data shall be preserved at all times..
- Purpose of Processing
Personal data collected by Töa Club Náutico may be used for the following purposes:- Managing reservation, pre-sale, purchase, membership, and payment processes.
- Complying with legal, contractual, accounting, and tax obligations.
- Sending information about the project, pre-sale phases, events, and progress updates.
- Managing user requests, claims, or inquiries.
- Conducting statistical, satisfaction, or behavioral analysis.
- Complying with legal requirements from ACODECO and other competent authorities.
- Sharing information with banks, insurance companies, notaries, and related providers while ensuring confidentiality.
- Sending commercial or promotional communications (subject to the user’s prior consent).
- Legal Basis for Processing
The processing of personal data by Töa Club Náutico is based on the following legal grounds:- Consent: Freely given by the data subject through the completion of forms or acceptance of processing.
- Contract performance: When processing is necessary to execute a pre-contractual or contractual relationship with the data subject.
- Legitimate interest: To improve services, customer experience, and communication.
- Legal obligation: When required by applicable law (e.g., tax or regulatory compliance).
- Data Subject Consent
The processing of personal data requires the prior, express, and informed consent of the data subject, except where legal exceptions apply.
Such consent may be provided through a signed document, digital acceptance (checkbox), verifiable email, or any other method demonstrating the individual’s intent.
- Data Subject Rights
In accordance with Law 81 of 2019, data subjects have the following rights:- Access: To know what personal data Töa Club Náutico holds.
- Rectification: To correct inaccurate or incomplete information.
- Erasure (Cancellation): To request deletion of data when the purpose no longer applies.
- Objection: To object to processing for legitimate reasons.
- Portability: To receive data in a structured format and transmit it to another controller.
- Requests must be submitted to contacto@toaclubnautico.com, including a valid identification document.
- Data Transfer and Disclosure
Personal data may be transferred to:- Financial institutions, notaries, or service providers involved in contractual execution.
- Competent public authorities, when legally required.
- Companies within the same corporate group, inside or outside Panama, under equivalent data protection principles.
- For international data transfers, Töa Club Náutico ensures that the recipient country maintains adequate protection standards or that the data
- subject’s consent has been obtained.
- Information Security
THE PROMOTER implements technical, administrative, and physical measures to prevent unauthorized access, loss, or alteration of personal data, including:- Secure servers and SSL/TLS encryption.
- Authentication protocols within IT systems.
- Restricted access for authorized personnel only.
- Regular data backups and periodic audits.
- Data Retention
Personal data will be retained for as long as necessary to fulfill the purposes for which it was collected or to comply with applicable legal obligations.
Once the purpose has been achieved, the data will be securely deleted or anonymized.
- Policy Updates
THE PROMOTER may update this Policy to reflect legal changes or new internal practices. Any modifications will be published on the official website.
- Applicable Law and Jurisdiction
This Policy is governed by the laws of the Republic of Panama, particularly Law 81 of 2019 on Personal Data Protection, Law 45 of 2007 (ACODECO).
Any disputes shall be resolved before the competent courts of Panama City, Republic of Panama.
Entry into Force
This Policy enters into force upon its official publication on Töa Club Náutico’s digital platforms.
Promotora Caribbean Coast Corp. - Töa Club Náutico Project
Website: www.toaclubnautico.com