Privacy

Last Updated: July 1, 2025

DL Vivento (“we,” “our,” or “us”) is deeply committed to protecting the privacy of your personal data. This Privacy Policy details how we collect, use, disclose, and safeguard your information when you visit our website (the “Website”) and engage with our services (the “Services”) related to purchasing a second home in the Dominican Republic and other select locations.

By accessing or using our Website and Services, you signify your understanding and acceptance of the data practices outlined in this policy.

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1. Important Information and Who We Are

DL Vivento acts as the Data Controller responsible for your personal data. This means we determine the purposes and means of processing your personal data.

Contact Details: For any questions regarding this Privacy Policy or to exercise your data protection rights, please contact us at: [email protected]

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2. The Data We Collect About You

We may collect, use, store, and transfer various types of personal data about you. This data is grouped into the following categories:

• Identity Data: Full name, marital status, title, date of birth, gender, nationality, passport details, national ID, and tax identification numbers.
• Contact Data: Billing address, delivery address, email address, and telephone numbers.
• Financial Data: Bank account details, payment card details, and details about the source of funds (crucial for Anti-Money Laundering (AML) compliance).
• Transaction Data: Details about payments to and from you, and other specifics of products and services you have purchased from us.
• Property Preference Data: Information concerning your desired property specifications, investment objectives, lifestyle needs, and interior design preferences.
• Technical Data: Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data: Information about how you use our website, products, and services (e.g., Browse patterns, pages visited).
• Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses, unless such collection is explicitly necessary and legally mandated for specific services (e.g., enhanced due diligence under AML laws).

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3. How Is Your Personal Data Collected?

We utilize various methods to collect data from and about you, including:

• Direct Interactions: You may provide us with your Identity, Contact, Financial, and Property Preference Data by filling in forms, engaging in correspondence with us via post, phone, email, or in-person meetings. This includes personal data you provide when you:
  • Inquire about our properties or services.
  • Engage us for realty services.
  • Engage us for interior design and execution services.
  • Engage us for legal support.
  • Request property management connections.
  • Subscribe to our newsletter, alerts, or other publications.
  • Participate in a competition, promotion, or survey.
  • Provide feedback or contact our support.
• Automated Technologies or Interactions: As you interact with our Website, we may automatically collect Technical Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
• Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources, including:
  • Technical Data from analytics providers (e.g., Google Analytics).
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
  • Identity and Contact Data from publicly available sources (e.g., public registers, social media platforms) for due diligence and marketing purposes.
  • Data from legal entities, financial institutions, and government bodies for compliance with Dominican Republic Anti-Money Laundering (AML) laws (Law No. 155-17).

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4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a Contract: Where processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract (e.g., facilitating a property purchase, providing design services).
• Legal Obligation: Where processing is necessary for compliance with a legal obligation that we are subject to, particularly under Dominican Republic Law No. 172-13 on the Protection of Personal Data and Law No. 155-17 against Money Laundering and the Financing of Terrorism.
• Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., improving our services, marketing, fraud prevention).
• Consent: Where required by law, we will obtain your explicit consent for specific processing activities. You have the right to withdraw consent at any time where we are relying on consent to process your personal data.

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5. Purposes for Which We Will Use Your Personal Data

We have outlined below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

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6. Disclosures of Your Personal Data

We may share your personal data with the following parties for the purposes set out above:

• Internal Third Parties: Our team members (e.g., María Elena Liriano, Sean Dalmasy, María Fernanda Ruiz) who require access to your information to perform their duties and provide you with services.
• External Third Parties:
  • Service Providers: Including legal advisors, financial institutions, property management companies, IT and system administration services, and other professionals who assist us in our operations. These third parties are obligated to process your personal data only on our instructions and in compliance with data protection laws.
  • Governmental and Regulatory Bodies: Including the Financial Intelligence Unit (FIU) of the Dominican Republic (Unidad de Análisis Financiero – UAF), tax authorities, and other relevant bodies, as required by law, especially for AML reporting obligations under Dominican Republic Law No. 155-17.
  • Professional Advisers: Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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7. International Transfers

We are based in the Dominican Republic. Your personal data may be stored and processed in the Dominican Republic and, where necessary for the provision of services, may be transferred to and stored in other countries where our service providers or partners are located.

When we transfer your personal data outside the Dominican Republic or the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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8. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so under both GDPR and Dominican Republic Law No. 172-13.

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9. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Specifically, in compliance with Dominican Republic Law No. 155-17 against Money Laundering and the Financing of Terrorism, we are generally required to retain certain client identification and transaction records for a minimum of ten (10) years following the termination of the business relationship.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

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10. Your Legal Rights

Under Dominican Republic Law No. 172-13 and the General Data Protection Regulation (GDPR), you have certain rights regarding your personal data. These rights include:

• The right to be informed: About how your personal data is being used.
• The right to access: To request a copy of the personal data we hold about you (also known as “Habeas Data” in the Dominican Republic).
• The right to rectification: To request that we correct any inaccurate or incomplete personal data we hold about you.
• The right to erasure (“right to be forgotten”): To request that we delete your personal data in certain circumstances. Please note that legal obligations (such as AML laws) may sometimes prevent immediate erasure.
• The right to restrict processing: To request that we suspend the processing of your personal data in certain circumstances.
• The right to data portability: To request the transfer of your personal data to another party.
• The right to object: To object to the processing of your personal data where we are relying on a legitimate interest or for direct marketing purposes.
• The right to withdraw consent: Where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please contact us using the details provided in Section 1. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You have the right to make a complaint at any time to the relevant data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us in the first instance.

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11. Cookies and Tracking Technologies

Our Website uses cookies and similar tracking technologies to enhance your Browse experience, analyze site usage, and support our marketing efforts.

• What are cookies? Cookies are small text files placed on your device by websites that you visit. They are widely used to make websites work more efficiently, as well as to provide information to the owners of the site.
• How we use cookies: We use cookies for purposes such as remembering your preferences, tracking your activity on our site (e.g., property searches, pages visited), and for analytics.
• Managing cookies: Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, as it will no longer be personalized to you. It may also stop you from saving customized settings like login information.

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12. Links to Third-Party Websites

Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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13. Children’s Privacy

Our Website and Services are not intended for children under the age of 18, and we do not knowingly collect personal data from children. If you are a parent or guardian and become aware that your child has provided us with personal data, please contact us, and we will take steps to remove that information from our servers.

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14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or relevant laws. We will notify you of any significant changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. You are advised to review this Privacy Policy periodically for any changes.