Privacy Policy

Last Updated: October 2024

Real Estate by Noel Ja Limited (“we,” “us,” or “our”) is committed to
protecting the privacy and security of your personal data. This Privacy
Policy outlines how we collect, use, disclose, and safeguard your
information in accordance with the Jamaica Data Protection Act (JDPA) 2020
and other applicable laws.

By using our website, interacting with us on social media, or engaging our
real estate services offline, you consent to the practices described in
this Policy.

1. Scope and Accountability

This Policy applies to all clients, website visitors, and third-party
vendors. As the Data Controller, Real Estate by Noel Ja Limited is
responsible for ensuring that your personal data is processed fairly,
transparently, and in compliance with the JDPA.

2. Information We Collect

Information You Provide Directly

• Contact Information: Name, email address, telephone number, and physical address.
• KYC Data: Government-issued ID, TRN, and proof of address.
• Property Preferences: Budget, desired location, and property specifications.
• Financial Information: Documents required for funds verification or transactions.

Information Collected Automatically

• Usage Data: IP address, browser type, pages visited, and visit duration.
• Cookies: Small files used to improve functionality and analyze traffic.

Information from Third Parties

We may receive information from financial institutions, legal
representatives, or public registries such as the National Land Agency to
facilitate real estate transactions.

3. Purpose of Processing

• Service Delivery: Facilitating the purchase, sale, or lease of property.
• Regulatory Compliance: Meeting AML and KYC requirements.
• Communication: Providing listing updates, newsletters, and inquiry responses.
• Internal Administration: Improving our website, managing inventory, and preventing fraud.

4. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with:

• Regulatory bodies such as the Real Estate Board of Jamaica and FID.
• Professional advisors including attorneys, surveyors, and financial institutions.
• Service providers such as IT hosts, marketing platforms, and analytics providers.
• Relevant parties in the event of a merger, acquisition, or asset sale.

5. International Transfers

If your data is transferred outside Jamaica, we ensure suitable safeguards
are used in accordance with the JDPA.

6. Your Rights Under the JDPA

• Right of Access
• Right to Rectification
• Right to Erasure
• Right to Object
• Right to Restrict Processing

7. Data Security

We use Privacy by Design principles, encryption, firewalls, and secure
access controls to protect your information.

8. Data Retention

We retain your personal data only as long as necessary, including legal,
accounting, or reporting requirements. Real estate transaction records may
typically be retained for up to 7 years.

9. Children’s Privacy

Our services are not directed to individuals under 18. We do not knowingly
collect personal data from minors.

10. Contact Us