PRIVACY POLICY

Effective Date: September 20, 2024

Palma Miami Beach LLC and its affiliated companies (collectively, “Company,” “we,” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy.  This privacy policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide to us, including information we may collect when you visit a website, use a web application or use a mobile app operated now or in the future by or for Company, including, without limitation the website located at www.palmamiamibeach.com (the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time.  Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

How to Revoke Your Consent or Request Information. 

You may revoke your consent on a going forward basis and submit written requests and questions about your rights to us by contacting us at:

Phone: +1 305.946.4264

Email: [email protected]  

Postal Address:

Palma Miami Beach LLC

Attn: Manager

7134 Carlyle Avenue

Miami Beach, FL 33141

The purpose of this Privacy Policy is to provide you with a comprehensive description of our practices regarding the collection, use, disclosure and sale of “Personal Information” (as defined below) and of your rights regarding your Personal Information.  This Privacy Policy applies to all Personal Information that we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website or the Company.
• Offline or in person, by phone, or through the submission by you of any form or document to the Company, whether the Company receives the form or document via electronic transmission, by mail, in person, or by any other means.
• Through mobile and desktop applications that we may provide that you download, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third party websites and services, of those applications or advertising include links to this policy.

Information We Collect, Why, and How We Use It

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”), including your name, phone number, e-mail address and/or physical address or other Personal Information that you submit to us while using the Website. Personal Information does not include:

• Publicly available information from government records and other sources.
• Deidentified or aggregated consumer information.

We collect Personal Information from the following categories of sources:

• Directly from You – We may collect information you provide to us, or that you authorize a third party to provide to us, including when you request information from us via the Website or submit an application to buy or rent a property from us, or any other form, whether electronic or paper; register on our Website; subscribe to receive alerts, newsletters, or event announcements; communicate with us by phone, e-mail or in person; register for or attend an event; or otherwise communicate with us.
• Indirectly from You – We may use cookies, pixel tags, web server logs and other security and surveillance technologies, identity confirmation technologies (such as caller ID) or other data collection technologies, including those described under the heading “Automatic Data Collection Technologies” below, to collect Personal Information about you when you visit our properties, use our Websites, or otherwise communicate or interact with our employees and service providers.
• Third Parties – We may obtain Personal Information about you from third parties, including, without limitation, from credit reporting agencies, employers, landlords, real estate sales professionals, social media platforms, and other third party sources.

The types of personal information we collect will depend on how you are interacting with our websites or at our locations.  Depending on our interactions, we may have collected the following categories of personal information within the past 12 months:

• When you contact us with questions or RSVP to an event: We may collect your name, email address, phone number, and payment card number and CVV (if applicable);
• When you visit us in person: We may collect your name, email, phone number, age, date of birth, and national origin or country of residence, as well as security camera footage in public areas;
• When you interact with us through our website: We may collect your IP address, information regarding your interaction with our website, and network location based on your IP address;
• When you interact with us on social media, including for giveaways: We may collect your name, phone number, social media handle/identifier, email address, and any correspondence you send or direct to us;
• When we market to you via email: We may collect information that is not linked to you, in order to help us provide relevant content. This information including your behavior as it relates to our emails, including whether emails were opened, deleted without opening, or whether you unsubscribed from our emails;
• When you inquire about purchasing or leasing a residential property: We may collect your name, phone number, current city, email, and information about your search criteria. When you purchase a residential property from us, we may also collect your passport or driver’s license number to verify your identity.

Certain personal information is required for specific services and if you fail to supply such personal information as requested from each specific service, we may not be able to deliver you the services or products.

Use and Sharing Personal Information

We may use your information to provide our products and services, such as providing information to you regarding our real estate projects and events related thereto. In addition, we may use your information for the following purposes:

• To operate, evaluate, and improve our website and business, including improving and personalizing the experience for you and others;
• For marketing campaigns, under certain circumstances, with your permission;
• To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback;
• To conduct data analytics in order to maintain and improve our offerings and to protect people who use our websites;

• For safety and security, including monitoring the technical functioning and security of our network;

• For legal and compliance, including complying with applicable laws, regulations, and legal obligations;
• To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights or property of the Company and its affiliates, its employees, and people who use the Website; and
• For such other purposes as you may consent (from time to time).

We do not share your Personal Information with third parties without your separate consent, except in the following circumstances and as described in this Privacy Policy: 

Affiliates.  We may share your Personal Information with our corporate parent, subsidiaries, and other affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your Personal Information with third party companies and individuals that provide services on our behalf or help us operate the Website (such as customer support, hosting, analytics, shipping, payment processing, email delivery, marketing, and database management services). These third parties may use your Personal Information only as directed or authorized by us and are prohibited from using or disclosing your information for any other purpose.

Partners. We may sometimes share your Personal Information with partners or enable partners to collect information directly via our Website. For example, we may share your Personal Information to selected third party entities that may review and use that information to send email messages or contact you in other ways to provide information to you about their products and services.

Professional advisors. We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Governmental authorities. We may disclose your Personal Information to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Websites and our products and services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Business transfers.  We may sell, transfer or otherwise share some or all of our business or assets, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution and may transfer your Personal Information as part of the transferred business or assets to the acquiror in such transaction.

“Sale” of Personal Information.  Like many companies, we use services that help deliver interest-based ads to you. We do not interpret the use of these services as a “sale” of your Personal Information to the companies that provide the services.  Although we allow the services to collect information from our Website users (e.g., online identifiers and browsing activity) so that they can help serve ads more likely to interest you, the information that is shared is either anonymous, aggregated or de-identified, or is shared pursuant to a service provider agreement.  To the extent California law treats these services as a “sale” of your Personal Information, the California Consumer Privacy Act of 2018, as amended, (the “CCPA”) prohibits third parties who purchase Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales. Although we do not treat services that help deliver interest-based ads as a “sale” of Personal Information, you may request to opt-out of targeted ads by following the directions set forth in the “Targeted Interest-Based Advertising” section below.  Except to the extent California law treats services that help deliver interest-based ads as a “sale” of Personal Information, we do not sell, rent, or otherwise make Personal Information commercially available to any third party and we do not share your Personal Information with unaffiliated third parties for promotional or advertising purposes.

Other Information We Collect

Our Website and online resources also collect other basic information about you that does not directly identify you, but which may correspond with you or a particular device (“Other Information”). We use this Other Information to learn more about how our Website is used and to improve or enhance the Website. We also use this information to customize the way information on our Website is presented to you. This information includes the IP address of your device; information regarding the pages on our Website that you have visited; time you spent on our Website; date and time of your visits; information about your web browser, device, and operating system; and location of the website visited just before our Website.

How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to treat Other Information as Personal Information under applicable law. In those situations, we may use and disclose Other Information for the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your IP address and information regarding the pages on our Website you have visited). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is so combined.

Automatic Collection Technologies

We use the following automatic collection technologies to collect Other Information, which may or may not be combined with Personal Information:

• Log Files: Most Internet browsers transmit certain information to websites that you visit, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files. We use this information to ensure that the Website functions properly.
• Cookies: Cookies are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer or smartphone) when you visit a website. Cookies allow us to recognize your browsing device and preferences and generally help to improve your online experience, as well as to provide us with anonymous information to check the usefulness of, and make improvements to, our Website. Cookies may be placed on your computer and/or mobile device by both us and by third parties with whom we have a relationship, such as web analytics services. You may refuse cookies by activating the setting on your browser. However, if you select this setting, you may not have the same user experience. To learn more about how to manage cookies, visit www.allaboutcookies.org/manage-cookies/ (please note that this website is not connected to us and we are not responsible for its content).
• Web Beacons and Pixel Tags: We may utilize a technology called a “web beacon” or “pixel tag.”  We may use web beacons to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site. 
• Third Party Analytics: We also may use automated devices and applications, such as Google Analytics to evaluate the use of our Website. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Website with other information they have collected for their own purposes. This Privacy Policy does not cover such uses of data by third parties. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports on our web traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms at  https://www.google.com/policies/privacy/. You can also find out more about how Google uses data at “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/ as well as their policies for safeguarding data at https://support.google.com/analytics/answer/6004245.  Additionally, the Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics (available at https://tools.google.com/dlpage/gaoptout/ and https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en).
• Do Not Track Signals: We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Your Choices About How We Use and Disclose Your Information

• Tracking Technologies and Advertising; Blocking Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Opting Out of Marketing Communications. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending your request to [email protected]. You can also always opt-out by following the opt-out or unsubscribe instructions at the bottom of the email.  Please note that such requests may take up to ten (10) business days to become effective.  You may continue to receive service-related and other non-marketing emails.  If you receive marketing text messages from us, you may be able to opt-out of receiving further marketing text messages from us by replying STOP to our marketing message, or by contacting us at [email protected].
• Telephone Communications. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
• Modify Your Information.  You may request to review, correct, update, suppress or otherwise modify any Personal Information that you have previously provided to us through the Website, or object to the use of such Personal Information by us.  For your protection, we will only implement requests with respect to the Personal Information associated with the particular individual if we can verify the identity of that individual (see “Exercising Access, Data Portability, and Deletion Rights” below for verification process). We aim to comply with requests as soon as reasonably practicable.
• Targeted Interest-Based Advertising. Some of the business partners that collect information about users’ activities on or through the Website may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.  You may stop or restrict the placement of cookies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.aboutads.info/choices/, https://youradchoices.ca/choices/,  www.networkadvertising.org/managing/opt_out.asp, and http://www.youronlinechoices.eu/. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

European Economic Area (EEA) Residents

We are located in the United States and the personal information we collect is stored in the United States.  This section applies to you if you live in the EEA. You may have the right to:

• Request access to your personal information, confirmation that we have information about you, and to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you if it is inaccurate or incomplete.
• Request erasure of your personal information, subject to certain limitations, where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where you believe we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.
• Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms under certain circumstances.
• Request restriction of processing of your personal information under certain circumstances if: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer (or portability) of your personal information to you or to a third party in a structured, commonly used, machine-readable format, in certain limited circumstances. Note that this right only applies to automated information which you initially provided for us to use or where we used the information to perform a contract with you.
• Withdraw consent, to the extent the processing of your personal information is based on your consent.
• Complain to a government regulator if you are not satisfied with our response, depending on your location.

Legal Bases For Processing

This section describes some of the legal bases we rely on to process your personal information. We may process your personal information for more than one legal basis depending on the specific purpose(s) for which we are using your personal information, including the following legal bases:

• Contracts. Where we need to perform the contract we are about to enter into or have entered into with you, including to provide you products or services.
• Legitimate Interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The following are non-exhaustive examples of where we rely on legitimate interest to process personal information:
• We have a legitimate interest in processing personal information relating to our existing customers in order to manage our business relationship and provide communications and information that may be of interest, including marketing communications.
• We have a legitimate interest in using cookies as outlined in this Privacy Policy. We have a legitimate interest in communicating with you to respond to and/or follow up on your requests, inquiries, issues, or feedback.
• Legal Obligations. Where we need to comply with a legal or regulatory obligation.
• Consent.  In some cases, we rely on your consent as a legal basis for processing your personal information.

Important Information for California Residents

The CCPA provides consumers who are California residents with specific rights regarding their Personal Information. This section applies if you are a California resident, and describes your CCPA rights and explains how to exercise those rights. These rights are not absolute and, in certain cases, we may decline your request as permitted by law.

“Legal Categories” of Personal Information

California law requires us to tell you about the Personal Information we collect about you in a certain way – specifically, we need to tie it back to “legal categories” of Personal Information that are listed in the law. To do this, we bundled up the information we gave you above in this Privacy Policy and matched the different types of Personal Information we collect about you with the legal category. Please note that certain pieces of Personal Information may fall into more than one of these categories.

To make things easier to understand, we’ve put this information in the table below that shows:

1. The legal category of Personal Information;
2. Examples of the types of Personal Information included in each legal category;
3. The source(s) from which we collect this type of Personal Information;
4. The purpose(s) for why we collect and use your Personal Information for each legal category; and
5. The categories of third parties with whom we share your Personal Information for a business purpose or for purposes of cross-context behavioral advertising.

We’ve included this information in the table provided below. As noted in the chart, some of the information is considered “sensitive Personal Information” (as defined by California law).

The categories of Personal Information we may have collected in the last twelve (12) months, the source of the information collected and the business purpose for collection are listed in the chart below. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. It is possible that we have not collected and/or will not collect information in a particular category.