Terra Sami B.V.
Version: 5 October 2026
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1. GENERAL PROVISIONS
### 1.1 Identity of the data controller
This privacy policy applies to the processing of personal data by:
**Terra Sami B.V.**
O2 Business Building – Parera
Fort Nassauweg, no number, unit A
Willemstad, Curaçao
Chamber of Commerce number: 172052
Email address: info@samiverde.com
Website: www.samiverde.com
### 1.2 Applicability
This privacy policy applies to all processing of personal data by Terra Sami B.V. (hereinafter: “Terra Sami”, “we” or “us”) in the course of its business activities in the property sector. This privacy policy describes what personal data we process, for what purposes, on what legal basis and how we handle this data.
### 1.3 Applicable legislation
This privacy policy and all processing of personal data by Terra Sami comply with the General Data Protection Regulation (GDPR) and other applicable data protection legislation. This privacy policy and the processing of personal data are governed by Dutch law.
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2. WHAT PERSONAL DATA DO WE PROCESS?
### 2.1 Categories of personal data
Terra Sami processes the following categories of personal data:
– **Name**: first name and surname
– **Email address**: for electronic communication
– **Telephone number**: for communication by telephone
### 2.2 Special categories of personal data
Terra Sami does not process any special categories of personal data as referred to in Article 9 of the GDPR (such as data relating to racial origin, ethnic origin, political opinions, religious or philosophical beliefs, health, sexual behaviour or sexual orientation, genetic data or biometric data).
### 2.3 Data relating to minors
Our services are not specifically aimed at persons under the age of 16. We do not knowingly process personal data relating to minors without the consent of a parent or guardian. If you suspect that we have collected such data, please contact us.
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3. SOURCE OF PERSONAL DATA
### 3.1 Direct provision
We process personal data that you provide to us via:
– The contact form on our website
– Direct communication by email or telephone
– Other forms of direct interaction with Terra Sami
### 3.2 No use of external sources
Terra Sami obtains personal data exclusively directly from the data subjects themselves and not via external sources or third parties.
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4. PURPOSES AND LEGAL BASES FOR DATA PROCESSING
### 4.1 Purposes of processing
Terra Sami processes your personal data solely for the following specific, clearly defined and legitimate purposes:
**a) Getting in touch and answering questions**
– Responding to enquiries sent to us via the contact form or by other means
– Corresponding with (prospective) customers and other stakeholders
– Providing information about our property services
### 4.2 Legal bases
The processing of your personal data is based on the following legal grounds as set out in Article 6 of the GDPR:
**a) Consent (Article 6(1)(a) of the GDPR)**
– By submitting the contact form or otherwise providing your details, you give your explicit consent to the processing of your personal data for the purposes set out above
– You have the right to withdraw your consent at any time
### 4.3 Limitation to necessary data
Terra Sami processes only the personal data necessary for the purposes set out above (data minimisation).
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5. DISCLOSURE TO THIRD PARTIES
### 5.1 No disclosure to third parties
Terra Sami does not disclose your personal data to third parties, except in the following exceptional circumstances:
– Where we are legally obliged to do so (for example, pursuant to a court order)
– Where this is necessary for the provision of our services and you have given your explicit consent
– Where this is necessary to protect our rights, property or safety, or those of our users or others
### 5.2 Data processors
Where Terra Sami engages third parties to process personal data on our behalf (data processors within the meaning of the GDPR), we enter into a data processing agreement with these parties in accordance with Article 28 of the GDPR, which sets out strict requirements regarding the security and confidentiality of your data.
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6. DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
Terra Sami does not disclose your personal data to parties outside the European Economic Area (EEA). Should we disclose data outside the EEA in the future, we will only do so if the requirements of Chapter V of the GDPR are met and after you have been informed of this.
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7. RETENTION PERIODS
### 7.1 General principle
Terra Sami does not retain your personal data for longer than is necessary for the purposes for which it was collected or as required by law.
### 7.2 Specific retention periods
Terra Sami applies the following retention periods:
**a) Customer and order details**
– Retention period: 7 years
– Legal basis: Tax retention obligation in accordance with the General Tax Act and the Civil Code
**b) Enquiries via the contact form**
– Retention period: 2 years after the last contact
– Purpose: Historical overview of communications and any follow-up
**c) Newsletter subscribers**
– Retention period: Until deregistration
– Once you have unsubscribed, your data will be deleted within 30 days
### 7.3 Disposal after the retention period
Once the retention periods mentioned above have expired, your personal data will be permanently deleted or anonymised, unless there is a legal obligation to retain the data for longer.
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8. PROTECTION OF PERSONAL DATA
### 8.1 Security measures
Terra Sami takes the protection of your personal data seriously and has put in place appropriate technical and organisational measures to safeguard personal data against loss, unauthorised access, unauthorised disclosure and other forms of unlawful processing.
### 8.2 Specific security measures
Terra Sami has implemented at least the following security measures:
**a) SSL/HTTPS encryption**
– All traffic between your browser and our website is encrypted using SSL/HTTPS technology
– This ensures that data sent via our website is protected against interception
**b) Restricted access**
– Only authorised Terra Sami staff have access to personal data
– Access is granted on a “need-to-know” basis
– Staff are bound by a duty of confidentiality
**c) Other measures**
– Regular updates and patches for the systems in use
– Logging and monitoring of access to systems containing personal data
– Secure data backups
### 8.3 Data breaches
Despite all security measures, a data breach may still occur. In the event of a data breach that is likely to pose a high risk to your rights and freedoms, we will report this to the Dutch Data Protection Authority within 72 hours and inform you accordingly, in accordance with the requirements of Articles 33 and 34 of the GDPR.
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9. COOKIES AND SIMILAR TECHNOLOGIES
### 9.1 What are cookies?
Cookies are small text files that are placed on your computer, tablet or smartphone when you visit our website. Cookies store information that can be recognised the next time you visit our website.
### 9.2 Types of cookies we use
Terra Sami uses the following types of cookies:
**a) Functional cookies**
– Purpose: These cookies are essential for the website to function
– Legal basis: Legitimate interest (Article 6(1)(f) of the GDPR)
– Consent: Not required (essential cookies)
– Examples: session cookies, security cookies, user preference cookies
**b) Analytical cookies (anonymised)**
– Purpose: To analyse visitor behaviour in order to improve our website
– Legal basis: Consent (Article 6(1)(a) of the GDPR)
– Terms and conditions: All analytical cookies are set in a fully anonymised form
– IP addresses are anonymised
– No data is shared with third parties
– Consent: Required via the cookie banner
### 9.3 Cookie banner and options
When you visit our website for the first time, a cookie banner will ask for your consent to the use of non-essential cookies. You can change your preferences at any time via the cookie settings on our website.
You have the following options:
– Accept all cookies
– Accept only functional (essential) cookies
– Set your preferences by category
### 9.4 Refusing and deleting cookies
You can also choose to refuse or delete cookies via your browser settings. Please note that refusing or deleting functional cookies may mean that certain parts of our website do not work (properly).
For further information on managing cookies, please refer to your browser’s help function or websites such as www.allaboutcookies.org or www.youronlinechoices.eu.
### 9.5 Cookie retention periods
Functional cookies are stored for as long as is necessary for the website to function (session cookies) or for a maximum of 1 year. Analytical cookies are stored for a maximum of 2 years.
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10. YOUR RIGHTS AS A DATA SUBJECT
### 10.1 Overview of your rights
Under the GDPR, as a data subject, you have the following rights in relation to your personal data:
1. Right of access (Article 15 of the GDPR)
2. Right to rectification (Article 16 of the GDPR)
3. Right to erasure/”right to be forgotten” (Article 17 of the GDPR)
4. Right to restriction of processing (Article 18 of the GDPR)
5. Right to data portability (Article 20 of the GDPR)
6. Right to object (Article 21 of the GDPR)
7. Right to withdraw consent (Article 7(3) of the GDPR)
8. Right to lodge a complaint with the supervisory authority (Article 77 of the GDPR)
### 10.2 Right of access
You have the right to know whether we process any of your personal data, and if so, which data. You may submit a request for access, following which we will provide you, within one month, with a full overview of all the personal data we process about you.
### 10.3 Right to rectification
If your personal data is incorrect or incomplete, you have the right to ask us to correct or complete it. We will do so within one month of receiving your request.
### 10.4 Right to erasure
Under certain circumstances, you have the right to ask us to erase your personal data, for example when:
– The data are no longer necessary for the purposes for which they were collected
– You withdraw your consent and there is no other legal basis for the processing
– You object to the processing and there are no compelling legitimate grounds for the processing
– The data has been processed unlawfully
– The data must be erased in order to comply with a legal obligation
This right is not absolute. We may refuse to comply with a request for data erasure if we have a legal obligation to retain the data (for example, under tax legislation) or if the processing is necessary for the establishment, exercise or defence of legal claims.
### 10.5 Right to restriction of processing
You have the right to request that we restrict the processing of your personal data where: