Privacy Policy

This Privacy Policy describes how The Wells Group ("we," "us," or "our") collects, uses, and shares information when you visit thesandsatpalawan.com (the "Site"). It also explains your rights with respect to that information under the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), and other applicable privacy laws.

By using the Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please discontinue use of the Site.

Contact for privacy inquiries: socalwells@gmail.com

1. Information We Collect

We collect only the personal information necessary to operate this Site and respond to your inquiries.

a. Information You Provide Directly

• Name and email address (when submitting an inquiry or requesting a brochure)
• Phone number (optional, if provided in a contact form)
• Country of residence and investor type (when submitting an inquiry)
• Any message content you submit through our contact forms

b. Information Collected Automatically

• IP address and approximate geographic location
• Browser type, operating system, and device information
• Pages visited, time spent on pages, and referral URLs
• Cookies and similar tracking technologies (see Section 5)

c. Special Categories of Data

We do not intentionally collect sensitive personal data such as health information, racial or ethnic origin, political opinions, religious beliefs, or biometric data.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your inquiries and send requested materials (e.g., the investment brochure)
• To communicate with you about the property and related investment opportunities
• To analyze Site usage and improve performance and user experience
• To comply with applicable legal obligations
• To prevent fraud and maintain the security of the Site

We will not use your information for any purpose incompatible with the purposes listed above without obtaining your prior consent.

3. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data under the following legal bases:

• Consent (Art. 6(1)(a) GDPR) — When you voluntarily submit a contact form or consent to receive marketing communications.
• Legitimate Interests (Art. 6(1)(f) GDPR) — To analyze Site usage for security and improvement purposes, where such interests are not overridden by your rights.
• Legal Obligation (Art. 6(1)(c) GDPR) — Where processing is required to comply with applicable law.

Where we rely on consent as the legal basis, you have the right to withdraw your consent at any time by contacting us at socalwells@gmail.com. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

4. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your information only in the following circumstances:

• Service Providers: We may share data with trusted third-party vendors who assist in operating the Site (e.g., hosting providers, email delivery services). These parties are contractually obligated to protect your data and use it only for the services they provide to us.
• Legal Requirements: We may disclose information if required by law, court order, or government authority, or to protect the rights, property, or safety of our business or others.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email or a prominent notice on the Site before your information is subject to a different privacy policy.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Site and understand how visitors use it. Cookies are small text files stored on your device.

Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Site to function. These cannot be disabled.
• Analytics Cookies: Help us understand Site usage (e.g., pages visited, traffic sources). Used only with your consent where required by law.

You may control cookie preferences through your browser settings. Most browsers allow you to refuse cookies or delete existing ones. Note that disabling cookies may affect Site functionality. Where required by law, we will seek your consent before placing non-essential cookies.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. In general:

• Inquiry and contact form data: up to 2 years from last contact
• Analytics data: up to 1 year, then anonymized
• Records required for legal or tax compliance: up to 7 years

When data is no longer needed, we securely delete or anonymize it.

7. International Data Transfers

This Site is operated from the United States. If you are accessing the Site from outside the United States, your information may be transferred to and processed in the United States or other countries where our service providers operate. These countries may not have the same data protection laws as your country of residence.

Where we transfer personal data from the EEA, UK, or Switzerland to countries that do not provide an adequate level of protection, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission.

8. Your Rights Under GDPR (EEA/UK Residents)

If you are located in the EEA or United Kingdom, you have the following rights under the GDPR:

• Right of Access (Art. 15): Request a copy of all personal data we hold about you.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
• Right to Erasure (Art. 17): Request deletion of your personal data, subject to legal retention requirements.
• Right to Restriction (Art. 18): Request that we limit how we use your data while a dispute is resolved.
• Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format.
• Right to Object (Art. 21): Object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time.

To exercise any of these rights, contact us at socalwells@gmail.com. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection supervisory authority.

9. California Privacy Rights (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you the following rights:

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, the business purpose, and the third parties with whom we share it.
• Right to Delete: Request deletion of your personal information, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: We do not sell or share personal information for cross-context behavioral advertising purposes. No opt-out is necessary, but you may contact us to confirm.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information beyond what is necessary to provide the requested services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

Categories of Personal Information Collected (Last 12 Months)

To submit a CCPA request, contact us at socalwells@gmail.com with the subject line "CCPA Privacy Request." We will verify your identity and respond within 45 days.

10. Children's Privacy

This Site is not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If you believe we have inadvertently collected data from a child, please contact us at socalwells@gmail.com and we will promptly delete it.

11. Security

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

12. Third-Party Links

The Site may contain links to third-party websites (e.g., wisdom.realtor). We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. For material changes, we will provide a more prominent notice. Your continued use of the Site after any changes constitutes acceptance of the updated policy.

14. Contact Us

For any privacy-related questions, requests, or complaints, please contact:

If you are an EEA resident and are unsatisfied with our response, you have the right to lodge a complaint with your national data protection authority (e.g., CNIL in France, ICO in the UK, or the relevant supervisory authority in your country).