Privacy Policy

The Company, with legal name Real Estate Los Guayabos Ltda., a Costa Rican company with registration number 3-102-487753, domiciled in San José, Curridabat (hereinafter, “Company” or “Controller”) owner of www.crnomads.com (hereinafter, “CR Nomads” or “Website”), provide by this Privacy Policy (Policy) a comprehensive description of the Company’s online and offline information practices.

This Policy shall also inform Users about the rights they have regarding their personal information and provide any information necessary for them to exercise those rights.

As used herein, Personal Information (PI) means any 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 individual (hereinafter, “User”).

Glossary

For the purposes of this Policy, the following terms shall have the following meanings:

Controller: the legal entity – Real Estate Los Guayabos Ltda.- that determines the purposes and means of processing personal data.
Services: content, advertising, and any functionality available on the Website to facilitate Users in connecting with Service Providers.
Service Providers: companies or professionals previously identified, verified, and validated by the Company, who wish to connect with Users and offer them their services on Website.
User or Nomad: Any natural person with the legal capacity, who visits, browses, and accesses www.crnomads.com and its Services, with the intention of contracting the services offered by Service Providers.1.- Declarations and scope of these Terms and Conditions.

1.- Personal Information we have collected and the purposes it had been collected

The Controller may collect PI from the User and use it for specified purposes. For a list of Categories of PI that Controller collects and the purposes for which the Company uses such PI, see the table below:

Categories of PI Collected	Purpose(s) for which it will be used
A.- Identifiers: Real name, alias, email, phone number, Internet Protocol Address (IP Address), passport number, driver’s license or state identification card number, self-portrait photograph.	To verify or authenticate User identity on CR Nomads, ensure compliance with government regulatory requirements, prevent fraud, respond to User requests, and provide Personal Information to Service Providers.
B.- Personal information categories: Profession, passport number, driver’s license, or state identification.	To respond any inquiry or application about the Services in Website, to verify or authenticate User identity in CR Nomads, to compliance with the regulatory requirements and fraud prevention activities.
C.- Protected classification characteristics under California or federal law and Information that reveals an individual’s racial or ethnic origin: Age, national origin, citizenship.	For compliance with government regulatory requirements on monitoring or demographic information collection and collected as part of an inquiry or application for Company Services.
D.- Commercial information: Location, Services searched or viewed in Website, travel dates, destinations to visit, other preferences, or consuming trends.	To responds to User request(s), to offer Services according with User buyer profile, to send email marketing campaigns to User.
E.- Internet or other similar network activity: Browsing history, search history on the Website, geolocation data, pages viewed, Service Provider pages viewed, metadata on a User’s interaction with CR Nomads, applications, or advertisements, and the content of personal messages sent to Company staff via instant messaging apps.	To improve Website usability and enhance the user experience, identify Services or Service Providers preferred by Users, monitor Website activity through web analytics, implement improvements to CR Nomads, respond to User requests, and provide the Services.
G.- Inferences drawn from other personal information: Information reflecting person’s preferences, characteristics, predispositions, behavior, lifestyle.	To responds to User request(s), to offer Services according with User buyer profile, to send email marketing campaigns to User, to improve CR Nomads Services and Service Providers, to create segmented marketing campaigns.

Company may also use or discloses the PI or sensitive PI collected for one or more of the following purposes:

To fulfill or meet the reason User provided the information. For example, if User share the name and contact information to request a quoted or more information about a Service Providers, ask a question about Company Services, CR Nomads will use that information to respond to User inquiry.
To facilitate the servicing, maintenance, or normal administration of the Services.
To provide support, personalize, and develop Website and services.
To provide User with support and to respond User inquiries, including to investigate and address User concerns and monitor and improve the Company services and customer services.
To help maintain the safety, security, and integrity of Websites, databases, and other technology assets.
To comply with regulatory requirements for collecting and retaining certain information, such as adhering to Know Your Customer (KYC) policies when applicable, based on the transactions made.
For testing, research, analysis, and product development, including to develop and improve the Website.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all Company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Company about our Users is among the assets transferred.

Company will not collect additional categories of PI or use the PI collected for materially different, unrelated, or incompatible purposes without providing notice to User.

2.- Selling or Sharing User’s Personal Information

While the Controller do not sell User’s PI for monetary value, may disclose PI to third parties, such as commercial partners, affiliates, Service Providers, dealers, contractors, IT service providers, ads providers or marketing agencies.

CR Nomads uses Google tracking, Google Advertising and Facebook Advertising products to improve its advertising efforts, including, but not limited to: Remarketing with Google Ads, Google Analytics, and Google Display Network. Google and Facebook use cookies to display CR Nomads ads based on our visitors’ past visits to the Website, other websites and their activity on Google.com, Facebook, Instagram. You may find out more about Google Advertising Policies or use their free opt-out tool. You can view your Facebook ad settings and update preferences at any time or opt out through the Digital Advertising Alliance.

The Controller may disclose all the information collected, as described above, to companies that perform marketing services on behalf of Company, such as service providers that provide marketing assistance or direct sales companies. Company may also enter into joint marketing agreements with others tourist agencies, to offer User a wide range of Services in Costa Rica according with User preferences.

The Company is also permitted by law to disclose information about Users to non-affiliated third parties in certain circumstances. For example, the Company may disclose information about Users to such third parties to assist CR Nomads in servicing Users, to protect against potential fraud or unauthorized transactions, in response to judicial processes, and to consumer reporting agencies.

3.- Retention of Personal Information

The length of time the Company will retain each category of User’s Personal Information (PI) depends on several criteria, including the duration required to comply with applicable regulatory requirements and the time needed to accomplish the Company’s commercial purposes for which the information is collected, used, or disclosed. However, the maximum retention period for PI will be 10 years after the User’s relationship with the Company has ended.

4.- User Rights

The User has the following rights regarding their personal data collected and processed by the Controller:

4.1.- Right to know

User may request that Controller disclose what personal information have collected, used, shared, or sold about User, and why CR Nomads collected, used, shared, or sold that information. Specifically, User may request that Controller disclose:

The categories of personal information collected.
Specific pieces of personal information collected.
The categories of sources from which the Controller collected personal information.
The purposes for which the Controller uses the personal information.
The categories of third parties with whom the Controller shares the personal information.
The categories of information that the Controller sells or discloses to third parties.

The Controller will provide to User this information for the 12-month period preceding the request for free of charge.

To request disclose to User what PI Controller have collected, User should contact Company sending an email to info@crnomads.com with all details about the request.

4.2.- Right to Delete Personal Information

The User may request the Controller to delete the Personal Information collected and to instruct their service providers to do the same. However, there are legal exceptions that allow the Controller to retain the User’s Personal Information. To request the deletion of User’s Personal Information, please contact the Controller by sending an email to info@crnomads.com with all details about the User’s request.

4.3.- Right to Correct Personal Information

The User may request the Controller to correct inaccurate information that they have about User. To request correct or update User’s PI, User should contact the Controller sending an email to info@crnomads.com with all details about your request.

4.4.- Right to Limit use Personal Information

The User may request to Controller to only use User sensitive PI (for example, passport number, or precise geolocation data) for limited purposes, such as providing User with the services requested.

To request limit use of PI, User should contact the Cotnroller sending an email to info@crnomads.com with all details about your request.

4.5.- Right to opt-out of the sale or sharing User Personal Information

The User may request the Controller to stop selling or sharing the User’s Personal Information (“opt-out”). Note that sharing refers specifically to sharing for cross-context behavioral advertising, which is the targeting of advertising to a user based on the User’s Personal Information obtained from the User’s online activity across numerous websites. With some exceptions, the Controller cannot sell or share the User’s Personal Information after the Company receives the User’s opt-out request unless the User later provides authorization allowing the Controller to do so again. The Controller must wait at least 12 months before asking the User to opt back in to the sale or sharing of the User’s Personal Information.

4.6.- Right to non-discrimination for exercising their rights.

The Controller cannot deny goods or services, charge a different price, or provide a different level or quality of goods or services just because User exercised rights under Privacy laws. However, if User refuses to provide PI to Company or asks to delete or stop selling User’s PI, and that personal information or sale is necessary for the Controller to provide User with goods or services, Company may not be able to complete that service or transaction.

The Controller may also offer promotions, discounts, and other deals to the User in exchange for collecting, retaining, or selling the User’s Personal Information. However, if the User requests the Controller to delete or stop selling their Personal Information, the User may not be able to continue participating in the special deals offered by the Company in exchange for Personal Information. If the User is unsure how the request may affect their participation in a special offer, please ask the Company for clarification.

To exercise any of these rights, User should send an email to info@crnomads.com, including all relevant information regarding their request.

5.- Cookies Policy

5.1.- What are cookies?

Cookies are any type of files created in the User’s browser to store and record data used on the User’s terminal device, with the purpose of storing information and retrieving previously stored information. Cookies allow the User’s device to store data amounts ranging from a few kilobytes to several megabytes.

5.2. Types of Cookies

This Website manages both first-party cookies and third-party cookies. The latter are sent to the User’s device from a device or domain not managed by the Company, but by another entity that processes data obtained through cookies.

Technical cookies: These cookies enable Users to navigate through a website, platform, or application and utilize the various options or services available. They are essential for the publisher to manage and operate the website, enabling its functions and services. For instance, these cookies control traffic and data communication, identify sessions, allow user authentication, grant access to restricted areas, remember elements comprising an order, facilitate the purchasing process of an order, manage payments, control fraud related to service security, and count visits for software licensing billing purposes that the Website operates with.
Behavioral Advertising Cookies: These cookies, processed by this Website or by third parties, allow the analysis of the User’s internet browsing habits to display advertising relevant to the User’s browsing profile.
Analysis or Measurement Cookies: These cookies enable the Controller or their third-party partners to track and analyze user behavior on linked websites, including quantifying the impacts of advertisements. The information collected through these cookies is used to measure the activity of websites, applications, or platforms, aiming to introduce improvements based on the analysis of usage data by the service’s users.
Preference or Customization Cookies: These cookies allow the retention of information to enable users to access the service with specific characteristics that distinguish their experience from other users. This may include language preferences, the number of results displayed when a user performs a search, the appearance or content of the service based on the type of browser used, or the region from which the user accesses the service, among others.

The following are the services that could install third-party cookies and process personal data of Users:

Service	Type of Cookies
Facebook	Analysis or measurement and behavioral advertising
Google	Analysis or measurement and behavioral advertising
WordPress	Analysis or measurement, preferences, or customization, and technical cookies: Authentication cookies, web beacons, embedded content, cookies for marketing or tracking.

5.3. How to Delete Cookies

Since Cookies are stored on the User’s hard drive and can be used by the browser at any time, the User can manually delete, or block stored cookies by following these procedures according to the browser they are using:

If the User wishes to browse this Website anonymously, they can do so using the TOR browser or utilize the BRAVE browser to block all types of advertising.

6.- Information Security

The Controller is dedicated to protecting the User’s Personal Information (PI) and takes all reasonable measures to do so. The Company requires trusted third parties handling User’s PI to implement appropriate measures based on identified risks. This includes signing confidentiality and data processing agreements, whether with internal collaborators or external providers.

The Controller endeavors to safeguard User’s PI to the best of its ability. Upon receipt of the User’s PI, strict procedures and security features are employed to prevent unauthorized access. The Company ensures the encryption of communications between the User’s device and its servers through the installation of SSL certificates.

However, as transmitting information over the internet is not entirely secure, the Controller cannot guarantee 100% security for data transmitted through CR Nomads. Therefore, any information transmitted is done at the User’s own risk.

7.- Third-Party external websites

If User accesses third-party services or external websites through CR Nomads.com, such as services associated with Google or social networks, these third-party contents, sites, or services might collect information about the User. The collection and processing of personal data by these third parties are governed by their own privacy policies. Therefore, the user acknowledges understanding that the treatment of data by these third parties is not the responsibility of CR Nomads.

8.- Changes to This Policy

The Controller reserves the right to add to, delete from, or otherwise change the terms of this Statement from time to time by posting a notice of the change (or an amended Statement) on this Website. If required by law, the Company will send a notice of the update to the User. The continued use of the Website by the User following notification will constitute the User’s agreement to the revised Statement.

9.- Questions or comments

For any questions regarding this Policy, or with Company privacy practices, please e-mail at info@crnomads.com.

Last update: May 2024