PRIVACY POLICY

This privacy policy (“Privacy Policy” or “Policy”) explains how  PMR Bahamas Realty, Ltd and PMR Bahamas, LLC d/b/a Torch Cay, LLC (collectively, “PMR”, “we” and “us”) process information on our websites and our digital applications and via offline forms that are linked to or contain the URL for this Privacy Policy (all of the foregoing, collectively, “Services”).   This Privacy Policy is incorporated into and subject to the Services’ Terms of Use. If you do not agree to the Terms of Use and this Privacy Policy, you must discontinue using the Services and all components and features therein. By using the Services, you acknowledge you have read and understand this Privacy Policy.

For the purposes of data protection laws, PMR is the data controller, 475 Fifth Avenue, New York, NY 10017

We obtain information from or about you when you use our Services. We may collect the following information about you or your use of the Services:

Information You Provide to Us:

• Registration, or Contact Information such as e-mail address, name, phone number and address
• Information you submit such as questions and other messages you address to us directly through the Service’s website, online forms, by email, over the phone, or by post
• Demographic, statistical and interest information such as your age, date of birth, gender, interests, lifestyle information, and hobbies
• Demographic, statistical and interest information such as your age, date of birth, gender, interests, lifestyle information, and hobbies
• Financial information, Employment or Education Information requested in connection with verifying your status as a qualified (or accredited) investor in connection with an application to acquire a membership interest in PMR Bahamas, LLC d/b/a Torch Cay, LLC, such as financial history, investments, bank account information, education history, employment experience or business contact information.
• Other information You Choose to Provide directly to PMR in connection with your use of the Services

Information We Collect Automatically:

• Device information and identifiers such as IP address; time zones, browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers
• Internet network and device activity data such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, products, goods or services viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information. See “Cookies and Other Tracking Technologies” below for more information about how we collect and use this information.
• Geolocation information such as city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation; time zones; and precise geolocation information from GPS-based functionality on your mobile devices, with your permission in accordance with your mobile device settings

Information from Third Parties:
We may also collect the information outlined above (except “Other Information You Choose to Provide”), such as contact information, demographic and social media information, from other sources such as public and commercial data sources, affiliates, marketers, social media networks, and third party advertising partners in accordance with your privacy preferences on such services. For example, when you “like” or “follow” us on Facebook, Instagram, Twitter, or other social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us depending on your settings. We also collect your information if you submit information to us through social media sites. We use this information to update, validate or supplement the information that you provide or we collected automatically, to target our communications so that we can inform you of products, services and offers that may be of interest, and for internal research, analytics and improvement of our Services.  

Depending on the Services you use and how you use them, we, or our service providers, may use your information to:

• Provide, manage, and improve the Services;
• Administer your account, including to process your applications and verify your information, including your status as a qualified (accredited) investor;
• Provide you with updates and information that you requested;
• Conduct internal business operations in support of our Services, such as auditing, security, resolving crashes, preventing fraud, invoicing and accounting, sales and marketing, analytics, and research and development;
• Contact you regarding our offerings, services, surveys, promotions, special events, and other subjects that we think may be of interest to you, including promotions, events and publications from our affiliates and their sponsors;
• Customize content and preferences for the Services;
• Comply with laws, regulations, and other legal process and procedures;
• Establish, exercise, or defend our legal rights; and
• Take steps that we reasonably believe to be necessary to protect the safety, security, and rights of PMR, its employees, service providers, and others.

PMR mayshare or disclose information collected from and about you on the Services to other companies or individuals as set forth below.

• Service Providers.  We may provide access to information to vendors that performservices on our behalf, including , managing our email lists and sending email messages on our behalf, providing customer support, analytics providers, and performing other administrative services, in order to carry out such services.  
• Our Affiliates. We may share information we collect within the extended PMR affiliates, including, for example, publications such as Robb Report,  to deliver products and services to you, ensure a consistent level of service across our Services, internal management and administrative purposes on our behalf and enhance our products, services, and your customer experience.
• For Marketing Purposes. We may share your information with partners whose offerings may interest you such as other marketers, retailers, participatory databases and non-profit organizations. This includes licensing information about your interests and activities, and marketing segments created with such data, which we may share with third parties for their marketing purposes.
• For Legal Purposes. By using the Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of PMR, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
• Sales or Transfer of Business or Assets. In connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise, including via bankruptcy) of all or a portion of the business conducted by the Website to which this policy applies, in which case the company will possess the information collected by us and will assume the rights and obligations regarding your information as described in this Privacy Policy (the “Acquisition Use”).
• Your Consent: If you have consented to our sharing of your information, we will also share your information consistent with your consent.

If you are a visitor from the European Economic Area, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it. We collect information from you:

• Where we need it to perform our contract with you (i.e. our Terms of Service) in order to provide the Services you request;
• Where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights) to secure our Services, prevent misuse, prevent fraud, and resolve technical issues; respond to your requests for information and provide you with more effective and efficient customer service; contact you regarding the Services, as well as surveys, promotions, special events, and other subjects that we think may be of interest to you (in accordance with applicable legal requirements); better understand your interests and improve our Services; personalize the Services; conduct internal business operations in support of our Services, such as auditing, sales and marketing, analytics, and research and development; and establish, exercise, or defend our legal rights.
• Where we have obtained your consent to send you marketing and other commercial communications and use non-strictly necessary cookies where local law requires such consent for such marketing and cookies (please note these requirements vary by jurisdiction and not all jurisdictions require consent for such uses) or use your information as set forth in a release or in connection with a consent; or
• Comply with our legal obligations.

We may also collect and use personal information in connection with your consent in other circumstances, which will be presented to you at the time of collection. You can revoke your consent at any time, though you might not be able to use a service or feature that requires collection or use of that personal information.

Marketing Emails. If you want to stop receiving promotional e-mails from us (which we send pursuant to applicable law),  click on the “unsubscribe” link in any promotional email from us. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. We may still send you transactional communications such as receipts or updates to this Privacy Policy or our Terms of Service.

‍SMS Text Communications. You may opt-out of SMS messages from us (which we send pursuant to applicable law) by following the instructions provided in the message or by texting back STOP to the number we send the text from for that particular SMS message. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.

‍Analytics. You may have the ability to accept or decline certain cookies for analytics on our Services depending on your jurisdiction. Some analytics providers we partner with may provide specific opt-out mechanisms.  For example, to prevent Google Analytics  from using your information for analytics via the Google Analytics Opt-out Browser Add-on.

‍Do Not Track. PMR does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on our Services.

‍Privacy Information for European Union, United Kingdom, Switzerland and other International Residents.  Residents of the European Union, United Kingdom, Switzerland have the right to request the following, and some residents of other countries outside the United States may also have such rights.   The laws of the EU, UK, Switzerland permit you to request and other  local laws may permit you to request that we:

• Provide access to and/or a copy of certain information we have about you;
• Prevent the processing of your information for direct-marketing purposes;
• Update information which is out of date or incorrect;
• Delete certain information which we have about you;
• Restrict the way that we process and disclose certain of your information;
• Transfer your information to a third-party provider of services; and
• Revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

If you would like like to request the above, please contact us using the information in the “Contact Us” section below at any time.

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

We use and allow certain other companies to use certain tracking technologies, including cookies, web beacons, and other similar technologies (collectively, “Cookies”) on the Services. To see an explanation what these technologies are and why we use them, as well as your rights to control our use of them please see our cookie notice (“Cookie Notice”). We endeavor to adhere to the Digital Advertising Alliance’s (DAA) self-regulatory principles governing interest-based advertising.

When you are on the Services, you may be directed to other websites that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. If you access a third-party website from the Services, you do so at your own risk, and you understand that this Privacy Policy does not apply to your use of such websites.

We implement appropriate administrative, technical and security safeguards to help prevent unauthorized access, use, or disclosure of the information we collect. However, no systems can be completely secure. Therefore, while PMR uses reasonable efforts to protect your information, PMR cannot guarantee its absolute security, and your use of the Services indicates your agreement to assume this risk.

The Services are for a general audience and are not designed or intended for use by children, especially those under age thirteen (13) or sixteen (16) in the EU.

The Services are operated in the United States of America (USA) and are intended for users located in the USA. If you are located outside of the USA, please note that the information you provide to us will be processed in the USA, where laws regarding processing of personal data may be less stringent than the laws in your country.  Where applicable law requires certain mechanims or safeguards prior to the transfer of data from another entity in antoher jurisdiction to the United States, we will implement such safeguards. 

We reserve the right to change this Privacy Policy at any time without prior notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy.

If you choose to access the Services, subscribe to our Publications or use any of our Services, any dispute over privacy is subject to our Terms of Use, including limitations on damages, resolution of disputes by binding arbitration, and application of the laws of the United States, and the State of New York. This Privacy Policy does not create rights enforceable by third parties.

If you have any questions or concerns about any aspect of this Privacy Policy, please contact our Data Privacy Officer at the address set forth below.Data Privacy Officer
PMR Bahamas Realty Ltd.
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475 Fifth AvenueNew York, NY 10017 Or PrivacyDirector@pmrc.com In addition, pursuant to Article 27 of the General Data Protection Regulation (GDPR), PMR has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

• by using EDPO’s online request form: https://edpo.com/gdpr-data-request/; or
• by writing to EDPO at Block 1, Blanchardstown Corporate Park, Ballycoolin Rd, Dublin D15 AKK1, Ireland.   

Cookies and Other Tracking TechnologiesWhat are Cookies? Cookies and other tracking technologies on the Services, including but not limited to web beacons/GIFs, pixels, and SDKs (together “Cookies” unless otherwise stated) are small files or technologies that are placed on tthat are placed on your computer or mobile device when you visit online site, service or app. They are used to recognize visitors across one or more browsing sessions and across one or more sites.. . Cookies help enable certain features (like remembering you so you do not have to re-log in), improve the Services, and deliver advertising.

We use cookies to:

• To control the display of, target, and measure ads;
• To analyze usage of the Services;
• To deliver website content;
• To enhance information we have about you; and
• To personalize information and marketing messages.

PMR Cookies can be set by the site or service you are visiting (“first-party cookies”) or by a third party, such as analytics (“third-party cookies”). Third parties may collect and use information as we have described in this Notice and our Privacy Policy and pursuant to their own privacy policies.

Types of Cookies
Our Services use the following types of first and third-party Cookies.  To make choices about Cookies, please follow the instructions below under the section Cookie Management
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• PMR Strictly Necessary  Cookies. These cookies are strictly necessary to allow you to move around the Services and use their features, such as accessing your subscriptions. Without these cookies, we cannot enable appropriate content based on the type of device you are using. Therefore, these cookies cannot be disabled.
• Functional Cookies.These cookies allow us to remember choices you make on our websites (such as your preferred language or the region you are in). If you disable functional cookies, you may not be able to use some of our features or those features may not function properly.
• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
• Analytics Cookies. We use Cookies to see how you use our Services in order to enhance their performance and develop them according to the preferences of our customers and visitors. For example, cookies may be used to maintain a consistent look and feel across our Services, track and provide trend analysis on how our users interact with our Services, track errors, to  try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Services, and to measure the effectiveness of our promotional campaigns..
• Third-Party Cookies. Some of our third party partners (including advertisers and marketing services companies) may set and access Cookies on your computer as well, or we may do so on their behalf. We do not have control over how these third parties use such Cookies or the information derived therefrom, and this Privacy Policy does not cover any use of information that such third parties may have collected from you or the methods used by the third-parties to collect that informationThese types of cookies include:
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  • Third-Party Functional Cookies. These Cookies are defined by third parties who support our Services and allow you to use useful services and features. 
• Web Beacons. Small graphic images or other web programming code called web beacons (also known as “clear GIFs” or “pixel tags”) or similar technologies may be included in our web pages and messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. A clear gif may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personally Identifiable Information. To refuse Web Beacons, please follow the instructions below under the section Cookie Management.
• HTML. HTML, the language some websites are coded in, may be used to store information on your computer or device about your interaction with and use of the Services. This information may be retrieved by us to help us manage our Services, such as by giving us information about how our Services are being used by our visitors, how they can be improved, and to customize them for our users.

Cookie Management.
You can use the methods described below to manage certain Cookies. You must take such steps on each browser or device that you use. If you change or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again. Some Cookie-management solutions also rely on Cookies, so please adjust your browser Cookie settings carefully. We do not maintain or control the third-party or browser or device level opt-out mechanisms and settings below and are not responsible for their operation.

• Depending on where you live, you may be able to adjust your Cookie preferences at any time via a “Manage Cookies” option by clicking on the green cookie icon in the lower-left corner of the website’s browser window (the text "Manage Preferences" will appear as the user scrolls over it.) 
• Analytics: To disable certain analytics Cookies, you can use the browser controls discussed above or, for some of our providers, you can use their individual opt-out mechanisms, such as the Google Analytics Opt-Out, Chartbeat at https://static.chartbeat.com/opt-out.html, and Comscore at https://www.scorecardresearch.com/optout.aspx?newlanguage=1.
• Using Browser Settings. You can disable and/or delete most types of cookies by using your browser settings. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our or others’ Services. The following links provide information on how to modify the cookies settings on some popular browsers:
  Apple
  Safari
  ‍Google
  Chrome
  ‍Microsoft Internet Explorer
  ‍Mozilla Firefox
• Mobile Settings: Your mobile device may also include settings that allow you to manage the use of cookies, such as Limit Ad Tracking or Tracking settings in iOS and Opt out of Ads Personalization in Android.
• If you have questions about the use of Cookies on our Services, please contact us as described in the Contact Us section of our Privacy Policy.

Consequences of Deactivation of Cookies: If you disable or remove Cookies, some parts of the Services may not function properly. Information may still be collected and used for other purposes, such as internal operations and to remember your opt-out preferences.