Privacy Policy

Effective Date: April 1, 2026  ·  Costa Blanca Villas, Farallón, Coclé, Panamá  ·  Governed by Ley No. 81 of March 26, 2019

1. Data Controller Identity

Costa Blanca Connect is operated as a private, closed community tool — not a commercial data-processing operation.

2. Legal Basis for Processing

In accordance with Ley No. 81 of 2019 (Ley sobre Protección de Datos Personales) and its implementing Executive Decree No. 285 of May 28, 2021, we process personal data under the following lawful bases:

• Consent: By creating an account and using this platform, you provide express, informed, and voluntary consent to the processing of your personal data for the purposes described herein.
• Contractual necessity: Processing is necessary to provide you access to the community platform you have requested.
• Legitimate interest: Maintaining platform security and community integrity constitutes a legitimate interest under Article 9 of Ley No. 81.

You may withdraw consent at any time by requesting account deletion. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

3. Personal Data We Collect — Full Disclosure

In compliance with Art. 5 and Art. 11 of Ley No. 81 of 2019, we provide this complete and transparent disclosure of every category of personal data we collect, the source of that data, and the purpose for which it is used.

3a. Data You Provide Directly

• Account registration: Username, display name, property/villa address, account role (neighbor, business, realtor, etc.), and any optional bio or profile description you choose to add.
• Posts and content: The full text of every post, comment, safety alert, listing, event, or recommendation you publish on the platform — including post type, category, and any tags or metadata associated with it.
• Reactions and interactions: Records of every reaction (like, agree, insightful, etc.) you place on any post or comment, and every neighbor connection you initiate or accept.
• Uploaded media: Images and photos you attach to posts or your profile, stored in their original form on the platform server.
• Business profile data (business accounts only): Business name, physical address, business category, operating hours, contact details, and any photos or descriptions submitted to the business directory.

3b. Data Collected Automatically

• Authentication session: A cryptographically signed session cookie is created when you log in. This cookie contains a session identifier only — no personal data — and expires when you log out or your session times out.
• Login activity: The date and time of each login, used solely for platform security and to detect unauthorized access attempts.
• Platform activity timestamps: The date and time posts and comments are created, edited, or deleted, retained as part of the community record.

3c. Data We Do NOT Collect

We explicitly do not collect the following, and have no technical mechanism to do so:

• Email addresses, phone numbers, or any contact information beyond what you voluntarily add to your profile
• Government-issued ID numbers, passport numbers, or Cédula numbers
• Financial data, payment information, or bank details of any kind
• Health, medical, or biometric data
• Device identifiers, IP addresses, or browser fingerprints
• GPS or precise location data
• Social media accounts or external platform credentials
• Behavioral tracking, advertising profiles, or browsing history

This platform does not use analytics tools, advertising networks, or any third-party tracking technology. No sensitive personal data as defined under Art. 7 of Ley No. 81 is collected or processed.

3d. How Your Data Is Used — Purpose Table

The following table maps each data category to its specific purpose and legal basis:

• Profile data → Display your identity to community members · Legal basis: Consent
• Posts & content → Populate the community feed and enable discussion · Legal basis: Consent / Contractual
• Reactions & connections → Enable social features and community engagement · Legal basis: Consent
• Uploaded media → Display images within posts and profiles · Legal basis: Consent
• Session cookie → Maintain your authenticated session securely · Legal basis: Contractual necessity
• Login timestamps → Detect unauthorized access and maintain security · Legal basis: Legitimate interest
• Activity timestamps → Maintain accurate community record and content chronology · Legal basis: Contractual necessity

4. Purpose of Processing

Personal data is processed exclusively for the following purposes and will not be used for any incompatible purpose without renewed consent:

• Displaying your profile and content to other verified community members
• Enabling community features including posts, comments, reactions, and neighbor connections
• Facilitating official community communications and platform governance
• Maintaining platform security and enforcing community standards

5. Data Sharing & Third Parties

Your personal data is never sold, rented, or disclosed to advertisers, data brokers, or any outside commercial party. Data is accessible only to:

• Verified members of the Costa Blanca Villas community (your posts and profile)
• Platform administrators (for moderation and governance purposes)
• Competent Panamanian authorities, if required by judicial order or legal obligation

Any transfer of personal data outside of Panama shall only be conducted to jurisdictions that provide an equivalent or higher level of protection in accordance with Art. 36 of Ley No. 81.

6. Data Retention

Personal data is retained for as long as your account is active, or as required to fulfill the purposes described above. In accordance with Art. 12 of Ley No. 81, data will not be retained beyond 7 years following the termination of your membership. Upon account deletion request, your personal profile data will be removed within 10 business days. Community posts may be anonymized rather than deleted to preserve community record integrity, unless you specifically request their removal.

7. Your Rights (Derechos ARCOP)

Under Ley No. 81 of 2019, you have the following rights with respect to your personal data, which we will fulfill within 10 business days of a verified request:

• Access (Acceso): Request a copy of the personal data we hold about you
• Rectification (Rectificación): Request correction of inaccurate or incomplete data
• Cancellation/Deletion (Cancelación): Request deletion of your data where it is no longer necessary or consent has been withdrawn
• Opposition (Oposición): Object to processing of your data in certain circumstances
• Portability (Portabilidad): Request your data in a structured, machine-readable format

To exercise any of these rights, contact the administrators through the official Costa Blanca Connect admin account on this platform. You also have the right to lodge a complaint with ANTAI (Autoridad Nacional de Transparencia y Acceso a la Información), the Panamanian data protection authority.

8. Cookies

We use a single, cryptographically signed session cookie solely for authentication purposes. We do not use tracking cookies, advertising pixels, analytics tools, or any third-party cookies. Your browsing activity within this platform is not tracked, profiled, or shared.

9. Security

We implement technical and organizational measures appropriate to the nature and scale of this platform, consistent with Art. 26 of Ley No. 81, including:

• Access restriction to verified, invitation-only community members
• Signed and encrypted session cookies
• File upload restrictions and size limitations
• Administrative access controls limited to designated platform administrators

In the event of a personal data security breach, we will notify ANTAI within 72 hours of discovery and will inform affected users as required by law.

10. Disclaimer of Liability

Costa Blanca Connect expressly disclaims liability to the fullest extent permitted by Panamanian law for:

• The accuracy, completeness, or reliability of any content posted by community members
• Any loss, harm, or dispute arising from member-to-member interactions, transactions, or communications conducted through or facilitated by this platform
• Unauthorized access to your account resulting from your failure to safeguard your credentials
• Service interruptions, data loss, or technical failures beyond our reasonable control
• Actions taken by third parties who gain access through your account or credentials
• Any reliance placed on safety alerts, recommendations, listings, or other user-generated content posted on this platform

This platform is provided as a community convenience tool on an "as-is" basis, without warranties of any kind, express or implied. Costa Blanca Connect does not endorse any goods, services, or recommendations posted by community members.

11. Children's Privacy

This platform is intended exclusively for adults aged 18 and over. We do not knowingly collect personal data from minors. If we become aware that a minor has registered an account without parental consent, we will delete that account promptly. If you believe a minor has submitted data to this platform, notify an administrator immediately.

12. Changes to This Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in law or platform operation. Material changes will be announced via the platform's community feed with reasonable advance notice. Continued use of the platform after the effective date of a revised policy constitutes your acceptance of the changes. The current version is always available on the login page.

13. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the República de Panamá, including Ley No. 81 of March 26, 2019 and its implementing regulations. Any disputes shall be subject to the exclusive jurisdiction of the competent courts of Coclé Province, Panamá.

14. Contact & Data Requests

All data subject requests, privacy concerns, or questions regarding this policy should be submitted through the official Costa Blanca Connect admin account on this platform, or by email to costablancavillaspanama@gmail.com. We will acknowledge your request within 3 business days and fulfill it within the 10-business-day period required by Ley No. 81.