Privacy Policy

Online Privacy Notice

1. Purpose of This Document 

1. This privacy notice sets out how Betty Boo Real Estate Sales (“Betty Boo”) fairly and lawfully processes Personal Data and also sets out the rights of individuals in respect of that Personal Data.

2. Betty Boo processes Personal Data that it gathers while operating the business of Betty Boo. Betty Boo may obtain Personal Data from you, your representatives or a third party connected with you in the ordinary course of Betty Boo’s business relationship with you, as well as Personal Data that has been made public, via the internet and subscription databases and other open-source materials.

2. Personal Data Collected & How it Will be Used
   1. Betty Boo collects the following Personal Data for the purposes set out below: 

1. contact details, including your name, address, email address and telephone numbers collected via email, forms online, or when receiving services which are required for client on boarding, relationship management and carry out obligations arising under any contracts by Betty Boo and its service providers;
2. information required by Betty Boo and its service providers to meet legal and regulatory requirements and obligations and legitimate interests in respect of anti-money laundering, sanction violation and fraud and other applicable legislation, including personal details required to identify and verify the identity of individuals – such as gender, marital status, date of birth, passport number(s), other government issued identification numbers, nationality, residency, citizenship, images of passports and driving licences, signatures, occupation, bank and personal references, biographical information, political or governmental positions held in the past of currently, source of funds and course of wealth;
3. information required by Betty Boo to meet legal and regulatory requirements relating to the automatic exchange of tax information (e.g. FACTA and CRS), including details of tax residency, tax classification and tax identification numbers;
4. financial details required for the process of administering Betty Boo’s relationship with you and for compliance with Betty Boo’s internal control framework, audit and risk management purposes, including: billing addressees; bank account numbers; instruction records; transaction and counterparty details required by Betty Boo, the Administrator or other service providers for such purposes; and
5. Personal Data contained in emails and cross-platform messaging, voice over IP services and telephone calls as you communicate with Betty Boo and our service providers.
6. Betty Boo will not routinely seek to collect or otherwise process sensitive Personal Data and will only do so in compliance with a legal obligation, for example to meet legal and regulatory requirements in respect of anti-money laundering legislation. 

3. Who we Might share your Personal Data With
   1. Betty Boo will disclose your Personal Data with other parties where such disclosure to the provider of services is considered necessary to fulfil the purposes set out above, subject to adequate contractual safeguards. Such disclosures of Personal Data may involve the transfer of data outside of the Cayman Islands, where Betty Boo is satisfied that adequate safeguards are in place.
   2. Betty Boo may share relevant Personal Data where it is lawful to do so including where:
4. it is necessary to comply with our contractual obligations or with your instructions;

2. we have a public or legal duty to do so (e.g. to assist with detecting and preventing fraud, tax evasion and financial crime or compliance with a court order);

3. we are obligated to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;

4. we are obligated to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;

5. we have asked you if we can share it, and you gave consent;

1. Service providers acting as processors who provide IT and system administration services anti-money laundering service providers and services to enable us to perform our contract with you;
2. Service providers acting as processors who provide IT and system administration services anti-money laundering service providers and services to enable us to perform our contract with you;
3. banks you instruct us to make payments to and receive payments from;
4. third parties who host the Website or provide services related to it, including IT security providers;
5. any people or companies where required in connection with potential or actual corporate restructuring, merge, acquisition or takeover, including any transfer or potential transfer of any of our rights or duties under our agreement with you;
6. 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;
7. other parties involved in any disputes, including disputed transactions;
8. fraud prevention agencies who’ll also use personal data to detect and prevent fraud and other financial crime and to verify your identity;
9. anyone who provides instructions to us on your behalf (e.g. under a Power of Attorney, solicitors, intermediaries, invest managers etc.);
10. anybody else that you instructed us to share your information with by you;
11. insurers who may provide cover for your investment with us.
12. Betty Boo has implemented appropriate technical and organisational measures designed to protect your Personal Data and will notify you and the Ombudsman in the event of a Personal Data Breach which is likely to prejudice your rights and freedoms. 

4. Information about the Website
   1. We may collect information about your computer (or mobile device), including where available you IP address, operating system and browser type, for system administration or for our own commercial purposes. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
   2.  We use cookies and similar technologies to distinguish you from other users of this site, to improve your experience when accessing this site, and to improve the site. Detailed information on the cookies we use and the purposes for which we use them are set out in our Cookie Policy.

5. Retention of Personal Data
   1. Betty Boo will only keep your Personal Data for as long as is necessary to fulfil any minimum statutory retention period. Betty Boo does not process Personal Data for direct marketing purposes and no Personal Data processing decisions are made by Betty Boo solely on an automated basis. 
   2. Where we share your personal data with third parties, the privacy notices and laws and regulations of the third party will determine how long they will have to retain your data.

6. Individual’s Rights
   1. Betty Boo is a Cayman Islands data controller and its data processing activities are governed by the Data Protection Act 2021 (the “DPA”) of the Cayman Islands.  You have a right to access and the right to request the amendment or rectification of your Personal Data held by Betty Boo, and in certain circumstance to request that Betty Boo ceases processing your Personal Data. You also have a right to complain to the Ombudsman about any perceived violation of the DPA by Betty Boo or its service providers, at info@ombudsman.ky.
   2. Any questions relating to this privacy notice, or access to or other rights in respect of your Personal Data should be directed to Betty Boo in the first instance, at bettyboo@candw.ky.

7. Miscellaneous 
   1. Please ensure that any data you give us or ask third parties to provide to us is up to date, accurate and complete in all respects. Please inform us about any changes as soon as reasonably possible.
   2. Betty Boo reserves the right to modify or amend this privacy notice at any time and an updated version of it will be placed on Betty Boo’s website.

8. Terms Used