Privacy policy

The controller of your personal data is Samana Group, Hacienda Cocuyo, Monte Rojo, Santa Bárbara de Samaná 32000, Dominican Republic. You can contact us about your data at hello@samana.group.

Samana Brokers (samanabrokers.com) is the offer of the Samana Group external sales department for property developers. The site and its visit counter are run by Samana Group.

When you visit the site, our hosting provider processes the technical data needed to deliver it, such as your IP address, browser information, the address requested and the time of the request.

We also count visits and clicks on the contact link, without cookies and without storing anything in your browser. When you open the home page and when you click the email link, your browser sends our server:

• the path of the page;
• the language version;
• where the click happened (the top of the page or the contact section);
• the UTM parameters from the address, if there are any (source, medium, campaign);
• a random visit identifier, created anew each time the page loads and not stored in your browser.

Our server saves this, with the date, in a database. These records contain no IP address, no browser (user agent) details, no cookie and no identifier of your device, and they do not allow us to identify you: they are anonymous statistics. Your IP address is used only briefly, in the server’s memory, to limit the number of requests, and it is not saved together with these records. Because the visit identifier changes with every page load, we cannot use it to recognise you on another visit.

When you send the enquiry form, we process:

• your name, company, email address and, if you give it, your phone number (required only if you ask us to contact you by WhatsApp or phone);
• how you prefer to be contacted;
• the details of your project: location, number of units, stage, unit price range, planned start of sales and your message, if you write one;
• the language version of the site and the UTM parameters from the address you came through, if there are any;
• the country determined from your IP address by our hosting provider;
• the date and time you sent the form and confirmed that you had read this policy;
• the result of the automated anti-bot check.

Your IP address and the check token are also sent to Cloudflare, which runs the anti-bot check. Sending the form also adds one anonymous row to the visit counter described above (the page “/lead”, the language version and the UTM parameters, if any), without any of your answers.

If you write to us by email, we process your email address, your name if you give it, and the content of your message, including anything else you tell us. Please do not include information you do not want us to have.

Analytics data is processed only if you choose “Accept all” (see the Cookie policy). Your choice about cookies is stored in your browser (see the Cookie policy).

• Delivering and securing the site (hosting, and limiting the number of requests, for which your IP address is used briefly in memory and not saved): our legitimate interest in the security of the site, Article 6(1)(f) GDPR.
• Aggregate statistics of visits and email clicks (the counter): the records are anonymous and do not identify you (see section 2), so this does not involve processing your personal data.
• Answering your email, including steps you ask us to take before entering into a contract: Article 6(1)(b) GDPR, and otherwise our legitimate interest in handling business enquiries, Article 6(1)(f) GDPR.
• Handling your enquiry from the form (answering it, contacting you about cooperation, recording the enquiry in our contact system, confirming it by email): taking steps at your request before entering into a contract, Article 6(1)(b) GDPR.
• Further business contact about cooperation (following up on your enquiry, including contact with you as a representative of your company): our legitimate interest in business-to-business contact about cooperation, Article 6(1)(f) GDPR. You can object to this (Article 21 GDPR, see section 7).
• Protecting the form against spam and abuse (Cloudflare Turnstile anti-bot check, request limits): our legitimate interest in protecting the form against spam, Article 6(1)(f) GDPR.
• Site statistics in Google Analytics, only if you choose “Accept all”: your consent, Article 6(1)(a) GDPR.
• Remembering your choice about cookies and being able to show it: our legitimate interest and our duty to demonstrate consent, Article 6(1)(f) and Article 7(1) GDPR.

Where we rely on your consent (Google Analytics only), you can withdraw it at any time with “Cookie settings” at the bottom of every page. Withdrawal does not affect processing carried out before it.

We share data only with providers who process it on our behalf, and only as far as needed:

• Vercel Inc. (USA): hosting of the site and server logs;
• Supabase Inc. (USA): the database in which the visit counter is kept; the database is located in the USA and is run by Samana Group;
• HighLevel, Inc. (USA): the customer relationship management system in which your enquiry is recorded;
• the provider of our automation server, which passes your enquiry to that system and to our team;
• Cloudflare, Inc. (USA): the Turnstile anti-bot check on the form (it receives the check token and your IP address);
• Calendly LLC (USA): scheduling of a call, only if you click the booking link on the confirmation page (your name and email address are then passed in the link);
• Google (Google Workspace): email service for the samana.group domain, through which we receive and answer your messages;
• Google LLC (USA): Google Analytics, only with your consent.

The Samana Group team that answers your email has access to your message.

Some of these providers are established in the United States, outside the European Economic Area, and Google may transfer analytics data outside it. Where data is transferred outside the EEA, the transfer relies on an adequacy decision (such as the EU-US Data Privacy Framework for certified providers) or on standard contractual clauses approved by the European Commission. You can ask us about these safeguards at hello@samana.group.

• Visit counter records: these records are anonymous (see section 2) and we keep them as statistics. The IP address used to limit the number of requests is not saved.
• Enquiries sent through the form: 24 months from our last contact with you, and afterwards only as long as we need them to establish, exercise or defend legal claims.
• Email correspondence: for the time needed to answer you and handle the matter, and afterwards only as long as we need it to establish, exercise or defend legal claims.
• Server logs: for the period set by our hosting provider.
• Google Analytics: the cookies last up to 2 years (see the Cookie policy).
• Your choice about cookies: until you change it or clear your browser data.

You have the right to access your data, to have it corrected or erased, to restrict its processing, to data portability and to object (Article 21 GDPR) to processing based on legitimate interest. You can exercise these rights by writing to hello@samana.group. The visit counter records are anonymous, so we cannot find or link any of them to you, and these rights cannot be exercised in relation to them.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live or work.

Giving your data is voluntary. You can use the site without writing to us. Without your email address and your message we cannot answer you. To send the enquiry form you must give your name, company, email address, the project details and tick the box confirming that you have read this policy; otherwise you can write to us by email. The visit counter works automatically and does not save anything that identifies you.

We do not make decisions based solely on automated processing, including profiling, that produce legal effects for you or similarly significantly affect you. The anti-bot check on the form only helps us recognise automated submissions.

We may update this policy. The date of the current version is shown at the top of this page.