PAN CARIBBEAN PRIVACY POLICY

Effective date: 1 October 2026
Last updated: 1 October 2026

1. About this Privacy Policy

Pan Caribbean Ltd ("Pan Caribbean", "we", "us" or "our") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, disclose and protect personal data when you use the Pan Caribbean website, applications, property search services, agent services, subscription services, artificial intelligence features and other products or services operated by us (together, the "Platform").

Pan Caribbean Ltd is a company registered in England and Wales under company number 17100850.

Registered office: [INSERT CURRENT REGISTERED OFFICE ADDRESS]
Email: info@pan-caribbean.com
Website: pan-caribbean.com

For the purposes of UK data protection law, Pan Caribbean Ltd is the data controller of the personal data described in this Privacy Policy unless otherwise stated.

2. Scope of this Policy

This Privacy Policy applies to:

• visitors browsing the Platform without registering;

• registered and paid users;

• prospective property buyers, sellers, tenants and investors;

• estate agents, brokers, developers, property owners and other property professionals;

• persons making enquiries through the Platform;

• persons subscribing to alerts, newsletters or other communications;

• users of Pan Caribbean's artificial intelligence and automated features; and

• other persons who interact with Pan Caribbean.

Individual estate agents, developers, lawyers, service providers and other businesses appearing on or contacted through the Platform may be independent data controllers in relation to information you provide directly to them. Their handling of your information will also be governed by their own privacy policies.

3. Personal Data We May Collect

Depending upon how you use the Platform, we may collect the following categories of personal data.

3.1 Identity and contact information

This may include:

• name;

• email address;

• telephone number;

• postal address;

• country of residence;

• username or account identifier;

• company or business name;

• professional role;

• agent, broker or developer details; and

• other contact information you choose to provide.

3.2 Account information

This may include:

• login information;

• encrypted or securely processed account credentials;

• account type;

• subscription status;

• profile information;

• account preferences;

• communication preferences;

• language preferences; and

• account activity.

We do not store passwords in readable form.

3.3 Property search and preference information

This may include:

• locations searched;

• preferred islands, countries or regions;

• property types;

• price ranges;

• bedroom or size preferences;

• lifestyle or investment preferences;

• saved searches;

• favourite properties;

• compared properties;

• search alerts;

• notes or other information entered by you; and

• interactions with listings.

3.4 Property enquiry and lead information

Where you enquire about a property or service, we may collect:

• the property concerned;

• your contact details;

• your message or enquiry;

• the date and time of your enquiry;

• your stated requirements;

• the agent or service provider contacted;

• responses and related communications where processed through the Platform; and

• information necessary to route, monitor or administer your enquiry.

3.5 Agent and listing information

If you are an agent, broker, developer, property owner or other listing provider, we may collect:

• professional contact information;

• agency or company details;

• licensing or professional information where applicable;

• property listing information;

• listing photographs, videos, floorplans and documents;

• lead information;

• subscription and billing information;

• profile information;

• records of listing activity; and

• communications with Pan Caribbean.

3.6 Payment and transaction information

Where you purchase a subscription, featured listing, advertising service or other paid service, we may process:

• subscription type;

• amount charged;

• transaction date;

• payment status;

• billing details;

• invoice information;

• refunds or adjustments; and

• limited payment identifiers supplied by our payment processor.

Payment-card details may be processed directly by third-party payment providers. Pan Caribbean does not ordinarily need to store complete payment-card details.

3.7 Communications

We may retain communications between you and Pan Caribbean, including:

• customer-support communications;

• complaints;

• feedback;

• emails;

• contact-form submissions;

• messages; and

• records of telephone or other communications where appropriate.

3.8 Reviews and user-generated content

Where the Platform permits reviews, comments, notes or other user-generated content, we may process the information you submit together with relevant account and moderation information.

3.9 Technical and usage information

When you use the Platform, we may automatically collect information such as:

• IP address;

• browser type and version;

• device type;

• operating system;

• device identifiers;

• approximate geographic location derived from technical information;

• referring website;

• pages and listings viewed;

• searches performed;

• links clicked;

• session information;

• login records;

• error logs;

• security information; and

• other information about how the Platform is used.

3.10 Location information

Where a Platform feature requires location information and you have permitted it, we may process location data to provide location-based searches, mapping or other relevant functionality.

You can normally control access to location data through your device or browser settings.

3.11 Artificial intelligence interactions

If you use an AI search, AI assistant, AI property chat or similar feature, we may process:

• prompts and questions you submit;

• property or search information associated with the interaction;

• AI responses;

• feedback about responses; and

• technical information necessary to operate, secure and improve the service.

You should not submit confidential, highly sensitive or unnecessary personal information through AI features.

3.12 Marketing information

We may record:

• whether you have subscribed to marketing;

• the communications you receive;

• whether communications are opened or interacted with;

• marketing preferences; and

• requests to unsubscribe.

4. Information We Do Not Intentionally Request

The Platform is not designed for the routine processing of special-category personal data such as information concerning health, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, genetic data or biometric information.

Please do not provide such information unless it is genuinely necessary and requested for a specific lawful purpose.

5. How We Obtain Personal Data

We may obtain personal data:

• directly from you;

• when you register or create an account;

• when you use or interact with the Platform;

• when you contact an agent or service provider through Pan Caribbean;

• from agents, developers, property professionals or other Platform participants;

• from payment providers;

• from analytics, security and technology providers;

• from publicly available sources where lawful;

• from third-party services you choose to connect to the Platform; and

• from cookies and similar technologies.

Where another person or organisation provides us with your personal data, we will process that information in accordance with applicable data protection law.

6. How and Why We Use Personal Data

We process personal data only where we have a lawful basis for doing so.

Our principal purposes and lawful bases include the following.

PurposeTypical lawful basisCreating and administering user accountsPerformance of a contractProviding property search and Platform functionalityPerformance of a contract and/or legitimate interestsOperating paid subscriptionsPerformance of a contractProviding saved searches, favourites and alertsPerformance of a contractProcessing property enquiries and routing leadsPerformance of a contract and/or legitimate interestsManaging agent accounts and property listingsPerformance of a contractProcessing payments and billingPerformance of a contract and legal obligationsProviding AI search, assistant and chat featuresPerformance of a contract and/or legitimate interestsProviding customer supportPerformance of a contract and legitimate interestsDetecting fraud, scraping, abuse or unauthorised accessLegitimate interestsProtecting Platform securityLegitimate interests and legal obligationsImproving Platform functionalityLegitimate interests and, where required, consentAnalyticsConsent where legally required and otherwise legitimate interestsDirect marketingConsent or legitimate interests where permitted by lawMaintaining accounting and tax recordsLegal obligationHandling legal claimsLegitimate interests and legal obligationsEnforcing our Terms & ConditionsLegitimate interests and performance of a contractPreventing infringement of intellectual property and database rightsLegitimate interestsComplying with legal or regulatory obligationsLegal obligation

Where we rely upon legitimate interests, those interests may include operating and improving Pan Caribbean, protecting our users and business, preventing fraud and misuse, developing Platform functionality, understanding Platform performance and protecting our intellectual property, database and commercial interests.

7. Property Enquiries and Sharing Information with Agents

If you choose to enquire about a property, request contact from an agent, developer or other provider, or otherwise ask us to connect you with a third party, we may disclose information reasonably necessary to respond to that request.

This may include your:

• name;

• contact information;

• property enquiry;

• stated requirements; and

• relevant property-search information.

Once your information has been provided to an independent agent, developer or other third party, that organisation may process it as a separate data controller under its own privacy arrangements.

Pan Caribbean is not responsible for an independent third party's use of information outside the Platform.

8. Artificial Intelligence and Automated Features

Pan Caribbean may use artificial intelligence, machine learning or automated technologies to provide features including:

• natural-language property search;

• property recommendations;

• property comparison;

• AI-assisted property information;

• listing assistance;

• market or search insights;

• agent tools;

• search refinement; and

• automated customer assistance.

Information submitted to these features may be processed by Pan Caribbean and, where necessary, specialist technology providers acting on our behalf or providing AI infrastructure.

We will seek to configure third-party providers so that personal information is handled appropriately and subject to applicable contractual and technical safeguards.

AI outputs can be inaccurate. Users should not include unnecessary confidential or sensitive personal data in AI prompts.

Unless expressly stated otherwise, Pan Caribbean does not use AI to make decisions about individuals that produce legal or similarly significant effects solely through automated processing.

9. Personalisation and Profiling

We may use information concerning searches, favourites, enquiries, property preferences and Platform activity to personalise:

• property results;

• recommendations;

• search functionality;

• alerts;

• content; and

• Platform experience.

Such personalisation does not ordinarily constitute solely automated decision-making producing legal or similarly significant effects.

10. Sharing Personal Data

We may share personal data where reasonably necessary with:

10.1 Property professionals

Including:

• estate agents;

• real estate brokers;

• developers;

• property owners;

• legal professionals;

• property service providers; and

• other businesses you ask to contact.

10.2 Technology and infrastructure providers

Including providers of:

• website and application hosting;

• cloud computing;

• data storage;

• databases;

• content delivery;

• cybersecurity;

• authentication;

• email delivery;

• customer support;

• analytics;

• mapping;

• artificial intelligence;

• communications; and

• software development and maintenance.

10.3 Payment and financial service providers

For the processing of payments, subscriptions, refunds, fraud prevention and billing.

10.4 Professional advisers

Including:

• lawyers;

• accountants;

• auditors;

• insurers; and

• professional consultants.

10.5 Regulators, authorities and courts

Where disclosure is required by law, legal process or a lawful request, or where reasonably necessary to establish, exercise or defend legal rights.

10.6 Business transfers

If Pan Caribbean or substantially all or part of its business or assets is sold, reorganised, merged, financed or transferred, relevant personal data may be disclosed to prospective or actual purchasers, investors or advisers subject to appropriate confidentiality safeguards.

We do not sell personal data simply for third parties to use for their own unrelated marketing purposes.

11. International Data Transfers

Pan Caribbean operates in relation to properties and businesses across multiple Caribbean jurisdictions and may use technology providers operating internationally.

As a result, personal data may sometimes be transferred or accessed outside the United Kingdom.

Where UK data protection law requires safeguards for an international transfer, we will use an appropriate mechanism such as:

• a country covered by UK adequacy regulations;

• the UK International Data Transfer Agreement;

• the UK Addendum to approved standard contractual clauses;

• another legally recognised transfer mechanism; or

• an applicable statutory derogation where appropriate.

You may contact us for further information about safeguards used for international transfers.

12. Data Storage and Security

We use reasonable and appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;

• accidental loss;

• destruction;

• misuse;

• alteration;

• disclosure; and

• unlawful processing.

Measures may include, where appropriate:

• encryption;

• access controls;

• authentication;

• secure cloud infrastructure;

• monitoring;

• backups;

• logging;

• staff and contractor access restrictions; and

• security testing.

No internet-based service can be guaranteed to be completely secure, and users remain responsible for keeping their account credentials confidential.

13. How Long We Keep Personal Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including legal, accounting, security and dispute-resolution requirements.

Typical retention considerations include:

Account information

Generally retained while the account remains active and for a reasonable period following closure where required for security, dispute or legal purposes.

Property enquiries and leads

Generally retained for the period reasonably necessary to administer the enquiry and maintain business records, subject to legal and commercial requirements.

Subscription and transaction records

May be retained for up to six years after the relevant financial period or transaction, or for another period required by applicable tax, accounting or legal obligations.

Customer-support and complaint records

Generally retained for as long as necessary to resolve the matter and thereafter for an appropriate period in case of subsequent dispute.

Marketing information

Retained until you unsubscribe or object, although we may retain a suppression record so that we know not to contact you again.

Security and technical logs

Generally retained for a limited period appropriate to security, fraud prevention, troubleshooting and legal requirements.

AI interactions

May be retained for a period reasonably necessary to provide, secure, monitor and improve the relevant AI service, subject to our contractual arrangements with technology providers.

Agent and listing records

May be retained during the agent relationship and afterwards where necessary for Platform integrity, legal claims, accounting, intellectual-property enforcement or dispute resolution.

We may retain anonymised or aggregated information indefinitely where it can no longer reasonably identify an individual.

14. Cookies and Similar Technologies

The Platform may use cookies, software development kits, pixels, local storage and similar technologies.

These technologies may be used for:

• essential Platform operation;

• security and authentication;

• remembering preferences;

• analytics;

• performance measurement;

• functionality; and

• advertising or marketing where applicable.

Strictly necessary technologies may be used without consent where permitted by law.

Where consent is legally required for non-essential cookies or similar technologies, they will not be activated until the user has been given appropriate information and has provided the required consent.

Users will be able to manage relevant choices through our cookie-management mechanism.

Further details should be provided in the Pan Caribbean Cookie Policy and cookie-preference centre.

15. Marketing Communications

Where permitted by law, we may send information about:

• property listings;

• Platform services;

• new features;

• subscriptions;

• property-market content;

• relevant offers; and

• other Pan Caribbean services.

You may unsubscribe from marketing emails using the unsubscribe mechanism provided in the communication or by contacting us.

Withdrawing marketing consent does not prevent us sending service communications necessary to administer your account, subscription, enquiry or other contractual relationship.

16. Your Data Protection Rights

Depending upon the circumstances and applicable law, you may have rights including:

• the right of access to personal data held about you;

• the right to rectification of inaccurate data;

• the right to erasure in certain circumstances;

• the right to restrict processing in certain circumstances;

• the right to data portability in certain circumstances;

• the right to object to certain processing;

• the right to withdraw consent where processing relies on consent; and

• rights relating to certain forms of automated decision-making.

These rights are not absolute and may be subject to statutory exceptions.

Important: right to object

You have the right to object at any time to the processing of your personal data for direct marketing purposes.

You may also have the right to object to processing based upon legitimate interests, depending upon the circumstances.

To exercise a right, contact:

info@pan-caribbean.com

We may need to verify your identity before acting on a request.

17. Account Deletion

Where account-deletion functionality is provided, deleting an account does not necessarily require immediate deletion of every record associated with that account.

We may retain information where reasonably necessary to:

• comply with law;

• maintain financial records;

• prevent fraud;

• enforce our Terms;

• protect intellectual property or database rights;

• maintain security;

• resolve disputes; or

• establish, exercise or defend legal claims.

Information no longer requiring identification may instead be deleted or anonymised.

18. Children

Pan Caribbean is intended principally for adults interested in property and property-related services.

Users creating paid accounts, listing property or entering contractual arrangements with Pan Caribbean must be at least 18 years old unless expressly agreed otherwise.

We do not knowingly seek to collect personal data from children for commercial property services.

If you believe a child has provided personal information to us inappropriately, please contact us.

19. Third-Party Websites and Services

The Platform may contain links to websites, applications and services operated by third parties.

Pan Caribbean does not control their privacy practices. Users should review the privacy policies of those third parties before providing personal information to them.

20. Changes to this Privacy Policy

We may update this Privacy Policy to reflect:

• changes to the Platform;

• new services or technologies;

• legal or regulatory developments; or

• changes to our data-processing practices.

The current version will be published on the Platform together with its effective or last-updated date.

Where a change materially affects how we process personal data, we will provide additional notice where required by law.

21. Complaints

If you have concerns about our use of your personal data, please contact us first at:

info@pan-caribbean.com

You also have the right to complain to the Information Commissioner's Office (ICO), the United Kingdom supervisory authority for data protection.

Information about making a complaint is available from the ICO.

22. Contact Us

For privacy enquiries or requests concerning your personal data:

Pan Caribbean Ltd
Company Number: 17100850
Email: info@pan-caribbean.com
Website: pan-caribbean.com